- Copies of three dedications to Alexis Valerie Hubbard in books by Hubbard

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Los Angeles, California; Wednesday, May 16, 1984; 9:47 a.m.

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THE COURT: All right, in the case on trial let the record reflect that counsel are present.

GERALD ARMSTRONG, resumed the stand, having been previously sworn, testified further as follows:

THE COURT: The witness has retaken the stand. Just state your name again for the record, sir. You are still under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: You may continue, Mr. Flynn.

MR. FLYNN: Thank you, Your Honor.

DIRECT EXAMINATION (Resumed) BY MR. FLYNN:

Q Now, Mr. Armstrong, do you recall letters that were written by Mr. Hubbard to the FBI and the Defense
Department in the mid-1950’s relative to Mr. Hubbard selling brainwashing techniques to the FBI which you sent to me?

A I sent you letters from that period which my recollection is were letters from Mr. Hubbard to the FBI and to other government agencies, and I do recall letters to the Defense Department. I don’t know if Mr. Hubbard in those letters stated that he was selling brainwashing to them.

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At times he claimed that he had a way of combating brainwashing. At other times it appears that he had the brainwashing technology. I don’t recall the way it is used in these letters. But it is on the subject of mental technology. And the term "brainwashing" or something similar is used within those letters.

Q And for what reason did you send that to me, those letters?

A They evidenced Mr. Hubbard’s continuing paranoia which was from the 1940’s through into the ’50’s and beyond. And they showed that Mr. Hubbard was claiming at that point to governmental personnel that the subject was a science; they showed contradictions between what he has claimed in other places publicly what Scientology is and what he was involved in and what his intentions were.

Q And are some of those materials set forth in exhibit 6C?

A Yes.

Q Turning now to exhibits 6E through 6Q which we went through quickly yesterday which called for — which recited in Mr. Hubbard’s handwriting that among other things, he should find the unsavory part of a person’s past and the criminal activities of a person’s past and pursue for harassment and items of that nature, when you sent those to me did you correlate the statements of Mr. Hubbard in those documents to statements that he had made in what has been marked exhibits 500 4D through 4G?

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MR. LITT: Objection, Your Honor.

THE COURT: Overruled.

THE WITNESS: Those 4D through 4G are the documents that we have called at various times the affirmations or the admissions, and there are some parts of those documents which were very significant to me, having to do with –

MR. LITT: Just a moment.

MR. FLYNN: Well, before you get into this, Your Honor, I’m going to do this on a very step-by-step basis, and then I will lay the foundation, and then I will inform the court of just several lines in the documents that correlate to these documents which the witness found extremely significant.

Q Now, did you find several statements by Mr. Hubbard in exhibit 4D through 4G that correlated to statements he had made in the 1960’s pertaining to attacks on enemies and the Fair Game Doctrine?

A Yes.

Q And those statements are in exhibits 4D through 4G; is that correct?

A Yes.

Q And what was your state of mind, Mr. Armstrong, when you found the documents in the 1960’s in Mr. Hubbard’s handwriting relative to attacking enemies?

THE COURT: Maybe you better identify what are you referring to now? Is this something in the 6 series?

MR. FLYNN: In exhibit 6.

THE COURT: Try to be a little more specific.

Q BY MR. FLYNN: 6E through 6Q.

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Now, in 6E you testified that Mr. Armstrong wrote about finding the criminal part or past of a particular individual; is that correct?

A Yes. It was Mr. Hubbard, yes.

This was a woman whose daughter had disconnected from her pursuant to Scientology policy, and Mr. Hubbard had ordered legal officer Branch 5 to investigate her past and psychiatrists’ past and find the criminal part — criminal past of these people.

Q Now at that time were you familiar with the Fair Game Doctrine that has been marked as an exhibit to lie, sue, cheat, and destroy enemies?

A Yes.

Q And in several other exhibits in Mr. Hubbard’s handwriting, did you find similar statements about finding the unsavory side of their past with reference to enemies?

A Yes.

THE COURT: Now, what exhibit do you have before you?

MR. FLYNN: That is 6F.

MR. LITT: Where is the word "enemy"?

BY MR. FLYNN: And would you read that part which refers to finding the unsavory side of their past?

MR. LITT: Let’s have the whole paragraph.

THE WITNESS: Okay.

"As we are having local counsel trouble, detach an investigator full time to that situation with orders to isolate the two or three members who give trouble and then to

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find the unsavory side of their past."

Q BY MR. FLYNN: Now, with regard to 6H did you find similar statements in Mr. Hubbard’s handwriting with regard to 6H?

MR. LITT: What is the date of 6H?

MR. FLYNN: 16 December ‘66.

THE WITNESS: Yes.

THE COURT: Well, what specifically did you find in that?

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Q BY MR. FLYNN: How many pages is 68, Mr. Armstrong?

A It is approximately 20.

Q And are there specific statements or does the document as a whole deal with attacking a particular
individual by a variety of means?

A Yes, they all have to do with attacking and the use of the courts. The final paragraph reads:

"If we play this right, these people go on trial, not us, and if we hit hard enough with our statement, we may never even have to appear in a courtroom."

Q Does that document also deal with finding information about a person’s past?

A Yes.

Q And is there a particular statement?

A There is here a number of — those whole thing refers to information which he wishes to make public about these people and there are allegations if you want me to read that.

Q Please do.

A (Reading:)

"Rather than just sue for libel, additionally our statement of charges must include the gory facts as follows: we have attached to them from the Ministry of Health a bitter man whom we have interviewed who goes around sending people off for electric shocks

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in his opinion if they look depressed, and he keeps a large number of the East Grinstead population on heavy drugs to which there is no end.

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"This can be added up into hypocrisy and a grave concern.

"counsel has no grave concern over the torture and death of their citizens by psychiatrists despite the fact that these people never get well after treatment.

"Psychiatry is a conspiracy to injure people so as to extort funds.

"If we use — I think it is –

"Werner’s Demand, we have it in writing for 100,000 pounds. The bribe not to stampede Parliament goes this way. He, a known blackmailer and head of the community for national health and national security, private group in Victoria.

"The theory behind our suits, the theory in all of this is that we must state the real problem and motive; only that blows it in the third dynamic. We cannot defend as they can come in with technology which can’t be tried in court; no technology can ever, as it is being tried before laymen; thus, if we can force them to countersue us for scare head charges, we can prove they go into heaven; they are since tried and not ours.

"We are very pale news copy. Theirs is sensational, injury, murder, extortion, insanity, misappropriation, aristocrat" — I don’t know what the next word is — "our objective is to cause

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Robinson to resign under a cloud just by filing a suit, to cause psychiatry to be looked on as an extortion racket that demands money under the threat of torture.

"You’ll find this will mob hysteria people. And to cause Bal Neil and the connected MP’s to resign.

Q MP’s is Ministers of Parliament?

A Members of Parliament.

"All of this on filing our suit statement, when we have mopped up here, we’ll go to Victoria and overthrow that one; then, South Africa and Rhodesia connection; thus, our statement must be violent. A well-placed attack should cause the enemy to prove our case by his actions.

"Religious prejudice is horrid to the English. So perchance that can be salted in.

"In short, if we do this right, we cause a political uproar, a stampede, against psychiatrists and enough resignations to make the enemy too weak to fight.

"If we merely defend, we have only to keep to draw back to.

"Now is the time for all our boiling oil before they batter in the main gate.

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"The dishonest always have left crimes lying around. So I set out to discover them. When somebody attacks Scientology, it happens accidentally. He almost always has a criminal past. That is our good fortune for all we need to do is expose it.

"So this is our basic theory behind these current suits. They are savage front line impact hitting at the real intentions. If we hit hard enough, they won’t really recover; therefore, I have been working out good screaming front-page news copy that we can back up. We take us off the stand and
put them on. It will take a lot of impact. This is not a court case. It is a filed statements case.

"They went to government, that private company, both national mental health association, to hit us. So we have to remove government from their line of attack.

"Counsel here used the NC planning" — that is, I believe, town and country planning — "to execute psychiatric attack on us. But how we prove it, I am not sure.

"Right wing is a spit word in world press today. So we must insert it where we can.

"If we could write, but we can’t,

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right wing torture groups run the largest multi-billion dollar extortion racket in history.

"Would make world headlines.

"We can, however, insinuate it any way we can. And thus snap left wing press over on our side. If we play this right, these people go on trial, not us, And if we hit hard enough with our statements, we may never even have to appear in a courtroom.

"The best.

"R.H."

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MR. LITT: Your Honor, may the record reflect that it took Mr. Armstrong approximately 10 minutes and that he was reading excerptions.

THE COURT: Well, I don’t know what the time was, but he did read. He left portions out. He read excerpts.

MR. FLYNN: Your Honor, we’d be more than happy to have the whole document go into evidence.

THE C0URT: Let’s not worry about that. Let’s just go on to the next question.

Q BY MR. FLYNN: Now, Mr. Armstrong, in exhibit 500 6J starting under paragraph eight, do you recognize that to be in the handwriting of L. Ron Hubbard?

A Yes.

Q And did you find similar times of requests by Mr. Hubbard to the organization to engage in the type of activity that you just read; namely, finding criminal past and activity of people to expose them?

A Yes.

Q And would you read that, please?

A There is a point here, number four, in a program on handling this particular problem of — it is an order to Mary Sue, and he is hiring a Pinkerton detective and one of the points is:

"We want evidence of collusion between the person who signed the warrant for Smith or his superiors and the APA or AMA" — American Psychiatric Association or American Medical Association –

"We want the name of every doctor who sought to

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get into this case and we want that doctor’s background. Trace it if possible to Communist connections or orders from APA under AMA.

"The operative should understand that we have been harassed by anti-American interests in many past cases and that this investigation is a routine assurance that we always take. We have traced 18 out of 22 persons publicly attacking us to criminal or Communist backgrounds."

This is the part you were referring to?

Q And is there a part in Mr. Hubbard’s handwriting where he states that:

"He should also understand that we are no crackpots. I am ex-B-3 of ONI. We hold the only systems that can raise pilot reaction time, increase the intelligence of scientists and counter-brainwash. Russia has been too interested in us since 1938 when they offered $100,000 for the basic use of Dianetics which when published in U.S. were hard hit by Commi-connected persons."

Q BY MR. FLYNN: 6P, "The suit is tactical. It is not in hope of gain. We must attack"; 6Q and 6R, and without going through the specific references in each and 6S dated October 8, 1961 relating to Michael Plynn and a psychiatrist named Dr. John Clark.

Now, when you found those materials, were you aware of the existence of the Fair Game Doctrine?

A Yes.

Q And at that time were you aware of the policy of the organization to cull PC files, auditing files to
collect information from people such as yourself?

A Yes.

MR. LITT: Such as yourself at the time? What are we talking about?

Q BY MR. FLYNN: Well, throughout the period of time that you were involved in the organization, Mr. Armstrong, did you understand that it was a regular practice to cull auditing files and gain information on people such as yourself?

A I only learned of that practice in 19 — late 1975.

Q And how did you learn of the practice?

A I was working in the Guardian’s office in Daytona Beach and I saw a great deal of correspondence, both Telex and written correspondence, which concerned people who were viewed as enemies or potential threats in the correspondence back and forth contained information taken from their PC files.

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Q And a PC file is what?

A During the process of auditing a person, a PC or preclear is asked questions by another person, and auditor, while the pre-clear holds the electrodes of an electronic mechanism which is basically a lie detector which measures galvanic skin response and other reactions. And the person, the PC, answers the auditors questions. And the questions can concern any part of his life, his history, his family, his thoughts, virtually every aspect, every person he has ever known, any familial connections, anyone of any significance in his life; any incident in his life. And all of this is written down in longhand in note form by the auditor complete with time, place, form, and event. And under some circumstances, when a Sec Check is being done, a lot of details are gathered so that the exact time, who knew about it, who was there, who should have known about it, any crimes, anything for which the person can be blackmailed, all of this stuff is recorded and those form the PC files, the auditing reports.

Q Now, at some time did you learn that there was a routine practice and a policy to cull those PC files by — cull the auditing files by the Guardian’s office and collect that information to be used against the people who had been audited?

A I learned of the practice when I was in the Guardian’s office in late 1975.

In 1976 and 1977 I was in the RPF in Clearwater.

And we were continually ordered to cull individuals’ PC files,

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people who either asked to leave or were viewed as a potential threat for whatever reason.

And anyone who asked to leave, their folders were culled for any crimes, for anything embarrassing, anything for which they could be blackmailed; a list of such crimes or incidents was typed up into a statement which the person had to sign before he could leave.

So I knew in 1975 of the practice of culling folders.

In 1976, ‘77, I was engaged in it on a continual basis as ordered by the Guardian’s office.

In 1978 in La Quinta I also participated in it.

And it wasn’t until after leaving the organization that I saw a written order concerning that policy.

But I had been — I knew that it was the policy.

And I participated in it; was ordered to participate in it for several years prior to that.

Q And that was one of the reasons that you left without routing out; is that correct, knowing that you would be forced to participate in that?

A That is correct.

Q And is this document under the name of Mary Sue Hubbard the policy that you saw later with regard to culling PC files?

MR. LITT: I’ll object, Your Honor. If he didn’t see it when he was in the Church of Scientology of California, what relevance does it have to anything that has to do with this case?

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THE COURT: Maybe to confirm the other part of his testimony. I don’t know what this is.
It is two pages of paper, printing.

THE WITNESS: Yes. This is the program order that I saw there.

Q BY MR. FLYNN: Do you wish to see it, Mr. Litt?

MR. LITT: No. I have seen it from you before, Mr. Flynn.

MR. FLYNN: May it be marked as next in order, Your Honor?

THE COURT: Okay. AAA.

Q BY MR. FLYNN: Now, on the second page of that policy it states, does it not, to –

MR. HARRIS: I’ll object to what it states, Your Honor.

This witness, after he leaves the organization, apparently gets this from Mr. Flynn who has passed it to Mr. Litt as well.

MR. FLYNN: I’ll withdraw it.

Q Is it your understanding, Mr. Armstrong, that that policy is consistent with the testimony you have just provided to the court?

A Yes.

Q What are processing files?

A Processing files are the auditing reports, PC folders, PC files.

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Q Now, when you read the handwritten papers of Mr. Hubbard and became aware of Mr. Hubbard’s instructing the organization to find a criminal past among other things, and when you were aware in 1980-81 of the practice of culling auditing files by the organization to use as you testified for purposes of blackmail, did you correlate that to statements made by Mr. Hubbard in exhibit 4D through 4G, 500 4d through 500 4G?

A Yes.

Q And what statement or statements did you correlate it to?

MR. LITT: Objection; is this a question about 4D et cetera or is this a question about 6?

THE COURT: I am not sure.

What do you mean by "correlate"?

BY MR. FLYNN: Did you understand that the practice to use information about a person’s past was used to control the person and to attack them mercilessly?

A Yes.

Q And did you find evidence of that in 4D through 4G?

MR. LITT: Just a yes or no.

THE COURT: You can answer it yes, no, or you don’t know.

THE WITNESS: I need to qualify it a little bit.

THE COURT: All right.

THE WITNESS: I did not find within 4D onwards the use of PC folders because that came later, but I did find

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information on the — Mr. Hubbard’s intention to be merciless toward people who countered him and his statement that he had the right to be merciless.

Q BY MR. FLYNN: And did you find a statement that "men are my slaves"?

MR. LITT: Just a moment, Your Honor.

THE COURT: I will sustain the objection. Let’s get the document out, what exhibit you have reference to. Let counsel see it and we will have a preliminary inquiry on whether –

MR. FLYNN: This will be the last reference, I believe, to this document.

MR. HARRIS: Thank goodness.

Q BY MR. FLYNN: While Miss Hart is trying to find that, Mr. Armstrong, was it your understanding from 1975 onward that Mr. Hubbard used information from PC files to control members of the organization?

A Yes.

Q And did you see that on a regular basis?

A Yes.

MR. LITT: You saw Mr. Hubbard?

Q BY MR. FLYNN: The organization on the orders of Mr. Hubbard; did you see that on a regular basis?

A Yes.

Q And can you find the reference?

And on 4D what is the eighth –

THE COURT: Do you have this exhibit 4D?

MR. LITT: Eighth page? My 4d has two parts to it.

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MR. FLYNN: There is no numbering.

THE COURT: Yes, it starts with "forced to" at the top.

Q BY MR. FLYNN: And on 4F –

THE COURT: Well, let’s do one thing at a time.

MR. LITT: Your Honor, after the court looks at it, I think we are going to have to look at your copy.

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THE COURT: Have counsel had a chance to find it?

MR. HARRIS: We’re not sure where it is, Your Honor.

THE COURT: You can approach the bench over here and you can refer to the Court’s exhibit.

MR. FLYNN: Your Honor, to save time, they might want to look at this part while they are at it.

I have a few more foundational questions, Your Honor, and then I would like to read the one sentence starting with "Men" and the other sentence starting with "You can be. . ."

THE COURT: Well, what are your questions that you want to ask?

Q BY MR. FLYNN: Mr. Armstrong, after you left the organization you knew that a Suppressive Person Declare had been issued on you; is that correct?

A Yes.

Q And I take it you were aware of the practice of culling PC files?

A Yes.

Q And was it your belief at the time that the organization had culled your auditing files?

A Yes.

Q And when you left the organization before the SP Declare was issued on you, what was your state of mind with regard to whether or not the organization would use those, PC files against you?

A I hoped that they wouldn’t, but I recognized that it was very likely.

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Q Now, is your entire life history and virtually every incident that you have been involved in in your life set forth in those PC files?

A Yes.

Q And when you were working or between 1980 and 1981 did you begin to have a developing awareness that you had been the slave of L. Ron Hubbard while you were working for $4 a week, 100 hours a week?

MR. LITT: Your Honor, this –

MR. HARRIS: His opinion, I guess.

MR. LITT: This is ridiculous. I mean –

THE COURT: It depends on the eye of the beholder what is ridiculous and what is not.

MR. LITT: Mr. Armstrong was voluntarily in the church while he was in the church. If he regrets it now, he is entitled to do so.

But are we going to have in testimony that he was a slave while he was in the church?

THE COURT: I suppose it is a conclusion.

MR. FLYNN: Your Honor, it does relate to the issue that Mr. Armstrong relied on extensive representations of Mr. Hubbard. Whether he was voluntarily in the church goes to whether he was defrauded and believed those representations to be true and later found them to be false.

The element of voluntariness goes to the element of misrepresentation.

MR. LITT: Which goes exactly to the religious fraud issue that we have said all along which is really at the heart

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of this theory.

MR. FLYNN: Whether L. Ron Hubbard is a nuclear physicist?

THE COURT: Gentlemen, you get off on these little tangents and get me away from the point we are trying to resolve.

Let’s go back and have the question read.

(The pending question was read.)

MR. LITT: I think the court sustained the objection.

THE COURT: It is a compound question as well as conclusionary; it is rather leading as well.

BY MR. FLYNN: What, if any, understanding did you have in connection with your working for L. Ron Hubbard between 1980 and 1981?

MR. HARRIS: We have been through this. This has been asked and answered before about a half dozen times. He thought he was working for L. Ron Hubbard.

THE COURT: I am not sure that is what counsel wants to develop at this time, having in mind his previous question.

BY MR. FLYNN: Specifically with reference to exhibit 4D through 4G –

MR. HARRIS: I’ll object. 352 at this point, for sure, Your Honor.

It is now cumulative and prejudicial. It outweighs any relevance. He has been through all of this before.

THE COURT: When did you first read these documents

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4D and 4E?

THE WITNESS: sometime in 1980.

THE COURT: Well, did that create any impression in your mind about your status in the church or in your relationship with Hr. Hubbard?

THE WITNESS: Your Honor, from that point onward there was a continuing and a growing awareness that I had been used and that I had continued to be used and that I had through representations and various physical and mental mechanisms, had been virtually enslaved by the man.

THE COURT: Ask your next question.

BY MR. FLYNN: And did you correlate that to Mr. Hubbard’s intentions which he set forth in his writing in 1946 as set forth in exhibit 4D and 4E?

MR. LITT: I’ll object, Your Honor. It is absolutely impossible for a reasonable person to draw any conclusions from those documents about this issue and what intentions are expressed.

The Court has read it and cannot reasonably draw a conclusion about what it means; so whatever conclusions Mr. Armstrong drew have to have been from other things. And under Section 352, we would ask that testimony of this be excluded. It is not reasonable. It is — you can’t reasonably construe that statement to mean anything.

The beginning of one of them, it says, "You are not accountable for anything that is said here."

So how is it that one can reasonably be relying on this?

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Whatever Mr. Armstrong relied on, it is not this.

And it is just an effort to get into what is extremely private and it should not be allowed. And it is not particularly germane to this case.

I just don’t think that the court should permit this constant effort to sort of push and push here and there to try to get portions of this document in.

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THE COURT: Well I think that the witness should be permitted and can be permitted to testify as to what his state of mind was. What his belief is and whether or not it is reasonable, that is for the court to conclude at a later date. If these had some bearing upon his state and mind and why he did what he did, it seems to me it is relevant and admissible. So, I will overrule the objection.

MR. LITT: Is the Court going to permit a reading from this?

THE COURT: Those excerpts and, of course, if you want in later testimony to develop the context or something to affect it, you may do so.

Please identify the exhibit that you are referring to before you do it.

MR. FLYNN: 4D, 500 4D.

Q It states, "Men are your slaves." Is that correct, Mr. Armstrong?

A Yes.

MR. LITT: Well, doesn’t the next sentence get read, too?

MR. FLYNN: We will read whatever you wish, Mr. Litt.

MR. LITT: Let me just take a look at it first.

Can I see that, please?

MR. FLYNN: Do you wish me to read it?

MR. LITT: The next sentence only.

MR. FLYNN: (Reading:)

"Elemental spirits are your slaves."

Q And referring to exhibit 4F it states, "You can

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be merciless whenever your will is crossed and you have the right to be merciless"; is that correct, Mr. Armstrong?

A Yes.

Q Now were you here when Mary Sue Hubbard testified that she was mentally raped by your having possession of the documents under seal?

A Yes.

Q And I believe you –

MR. HARRIS: I think that misstates the testimony.

She was mentally raped because he sent them to Mr. Flynn, Your Honor.

THE COURT: I am not quite sure. It sounds like that is my recollection, but we have the actual words here. Let’s go on. That is just a point of reference.

Q BY MR. FLYNN: Now, as you sit here on the witness stand today and prior to your cross-examination, you are aware that all of your PC files are in the possession of the plaintiff in this action; is that correct?

A Yes.

Q And when the SP Declare was issued on you, were you fearful of that fact?

A Yes.

THE COURT: Well, when the PC goes into an auditing session, are there any representations made whether or not anything he says is in confidence or is he under an understanding that everything he says is going to be available for later use?

THE WITNESS: Your Honor, when I first became involved

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in Scientology, I asked on that specific point and there are representations made within Scientology literature and by Mr. Hubbard that the information is kept confidential.

It wasn’t until some six or seven years later that I learned that, in fact, it was available for use by the Intelligence Bureau of the organization, and the fact that it was used, could be used however they wanted.

THE COURT: Did you rely upon those representations of confidence?

THE WITNESS: The initial ones?

THE COURT:Yes.

THE WITNESS: Yes.

THE COURT: All right, you may continue, counsel.

BY MR. FLYNN: Now, the policy of representation is set forth in several publications, including the Auditors Code; is that correct?

A Yes.

Q Now under what circumstances did exhibit 500 6S "Estimate in Reader’s Digest" come into your hands?

A This was provided to me to give to Mr. Garrison by Vaughn Young sometime in the fall of 1981.

Q And did you read it at that time?

A Yes.

Q Did you provide it to Mr. Garrison?

A Yes.

Q And did that confirm your understanding that the organization was, as you put it, acting as an intelligence agency in collecting hundreds of files on people including me?

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A Yes.

Q And with respect to a list of people, including Michael Flynn, Paulette Cooper, Reader’s Digest, Rockefeller, L., Margaret Singer, Nan McLean, Eugene Methvin, and John Clark, was there an indication that 30 feet of information had been gone through and 200 files to make up a set of index files?

A Yes.

Q And did you check the accuracy at any time of the information contained in exhibit 6S?

MR. HARRIS: "At any time" while he had it in his possession or before he left the church or at any time in Mr. Flynn’s office? What is the reference, Your Honor?

Q BY MR. FLYNN: Before you left the church, did you attempt to try to check the accuracy of exhibit 6S?

A I don’t believe that I did anything at that time.

I provided it to Mr. Garrison with — I had understood that it was accurate at that tine, that everything that was laid out here was exactly — not that the substance o£ the reports were accurate because I had by that time begun to perceive that, in fact, there were no enemies who sere out to get Scientology, that that was a created mechanism by which to keep the troups in line.

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But I assumed that the information given on the amount of data collection and amount of volume of the files which were examined in order to come up with this estimate were accurate.

Q And after you left the organization, when you were working for Mr. Garrison, did you make any efforts to ascertain the accuracy of the contents of the exhibit 6S?

A I believe only in — I questioned you as to the accuracy of some of the allegations in here, the connections to the Rockefellers and to John Clark.

Q And did exhibit 6S confirm for you that the organization had been collecting files on people such as myself?

A Yes. I already knew that. So it never really acted as a confirmation so much.

The mass of it, I was not perhaps totally aware of. But it was a — it was just another fact which was added to the already growing awareness of these activities.

I myself was in the Intelligence Bureau both on the ship and in Daytona. So I was already drilled in intelligence acitivities and on data collection, so forth.

Q What was your state of mind before you left the organization, Mr. Armstrong, with regard to how the intelligence agency of the church collected information on people such as myself?

A Well, they used whatever source, either covert or overt in the data collection.

Overt data collection would simply be going

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through old newspapers or public reports or all the — in your case, going through all the files for any trial which you had been involved in; examining the backgrounds of your clients, of your family. This would be involved with an overt data collection.

Then there would be a covert data collection which would be getting someone in close to you, putting a plant in your office; putting a plant in the office of someone connected to you.

MR. LITT: These are –

MR. HARRIS: Let him go. It is state of mind.

Q BY MR. FLYNN: Go ahead.

MR. HARRIS: This is being offered for state of mind, as I understand it?

THE COURT: Well, I don’t recall at this point.

Q BY M. FLYNN: The question was specifically what was your state of mind; is that correct, Mr. Armstrong, before you left the organization with regard to how information is collected by the church?

A Right. This is what I knew at the time on the methods of data collection, the specifics of how that would be done. As an intelligence personnel, this is how I would go about collecting information on you and which I knew the organization, if they were collecting information on you, would go about doing it.

Q Did it range from outright burglary to looking up in newspapers, collecting information?

MR. LITT: Objection.

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THE COURT: I don’t know what "outright burglary" is.

I have heard of a righteous burglary.

Q BY MR. FLYNN: What was your understanding as to the means the organization used, Mr. Armstrong?

MR. HARRIS: His state of mind as to the means; is that the question, rather than understanding?

THE COURT: I guess it is state of mind, Understanding is a state of mind; belief is a state of mind; knowledge is a state of mind.

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THE WITNESS: Data collection which I have mentioned and within covert activities such as burglary, theft, plants, blackmail.

Q BY MR. FLYNN: And did you understand that to be an ongoing practice of the organization throughout the period of time that you were involved?

A I did not know of it probably until some time in probably 1980. I became very aware of the extent of the covert intelligence activities.

Q And was that a factor with regard to giving or sending to me all of the documents that you sent to me; namely, the organization’s collection and use of information against enemies?

A Yes.

Q And at that time you perceived yourself to be an enemy; is that correct?

A Yes. I should say that I believed that they perceived me to be an enemy.

Q And why did you send me exhibit 500-6T?

A This covers a time when Mr. Hubbard was on probation, I believe in 1950 or 1951 in San Luis Obispo, I believe, although I am not sure. I can’t see there.

In any case, it showed that Hr. Hubbard had been apparently convicted of a crime or a misdemeanor or something and had been put on probation in 1950.

Q And with regard to exhibit 500-6U, why did you send me those collection of pictures with a dispatch from a Terry Milner?

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A This is a letter from the then DGNF US.

That is the head of the intelligence bureau in the United States, and it was addressed via Mary Sue to Ken Urquhart was the LRH personal communicator on board the ship at that point. It is dated 25 September, 1973, and it concerns the photos which are in this envelope here and indicated that the — it states that the photos — it says, "Actually most of it belonged to Nibs."

Nibs was L. Ron Hubbard, Jr., and I knew of the - that Nibs or L. Ron Hubbard, Jr. was viewed as an enemy by the organization, and there was a possibility from this dispatch that these photos had been stolen from Nibs. Hence I sent it to you.

Q And did you determine whether or not there was a conflicting claim between the organization as to whether Nibs had given the photos voluntarily or as to whether they had been stolen and whether anybody had been requested to sign a particular document with respect to them?

MR. HARRIS: That is about three compound questions, Your Honor.

MR. FLYNN: I will withdraw it, Your Honor.

Q What if anything, did you learn about the dispute over these photographs, Mr. Armstrong?

A I don’t know of a dispute over the photographs.

However, in connection with — or a conversation with Nibs, he said –

MR. LITT: Can we have a time frame here.

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THE WITNESS: Yes, this was probably a month ago, something like that.

MR. LITT: Your Honor, this is supposed to be why he sent these things. It was done well before a month ago.

THE COURT: Well, he’s already testified. This goes to something else, but I don’t know if it is terribly relevant.

MR. LITT: It is hearsay.

MR. FLYNN: I will withdraw it.

THE COURT: Let’s take a 10-minute recess.

(Recess.)

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THE COURT: In the case on trial, let the record reflect that counsel are present; the witness has retaken the stand. State your name again for the record, sir. You are still under oath.

THE WITNESS: Gerald Armstrong.

MR. FLYNN: Your Honor, I think I am very close to completing the direct examination.

Q Mr. Armstrong, with regard to 500 6V through 500 6Y, did you send those to me to assist in the defense of the claims that the organization vas making against you?

A Yes.

Q And with regard to 500 6Z, why did you send my office that?

A This file contained a number of blank pieces of stationery, one from U.S. Naval Hospital and another, a letter, apparently, on Explorer Club stationery and signed by a Robert Lees. And it is sort of a letter of recommendation for Mr. Hubbard.

My belief is that Mr. Hubbard in fact wrote it and signed it for Mr. Lees.

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I sent you this stuff because I had come across in the course of this biography research a number of such documents which appear that Mr. Hubbard had written on someone else’s letterhead, letters for himself or had filled in for someone else, and in one case a fitness report and in another case a statement of the medals that he had earned during the war, and that was just to me a small evidence of the type of fraud is which Mr. Hubbard engaged.

Q Now, is one of those documents that you referred in your last answer a document involving a Commander Thompson which is not under seal?

A Yes.

MR: LITT: Would you say that again? I missed that.

THE COURT: Which is not under seal.

MR. LITT: Is one of those documents in 6-V not under seal? Is that the question?

MR. FLYNN: No.

Q Is one of the documents you referred to that evidenced Mr. Hubbard’s signing someone else’s name as evidence of the fraudulent activity of Mr. Hubbard not under seal?

A Yes.

Q And where did you last see it?

A Inside the organization.

Q And what is that document?

A It was a — either a fitness report or something similar around the time of the end of the war,

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and there is a signature on it by a Commander Thompson, and the signature, my recollection is, is done in a broad blue pencil crayon or a blue marker of some sort, not a felt marker but a crayon marker, and I had other materials from that period in Mr. Hubbard’s writing which were also done with this same marker.

THE COURT: I think it is probably conclusionary.

You can say it is a similar marker.

THE WITNESS: That is correct, Your Honor.

Q BY MR. FLYNN: Now did this document contain representations about Mr. Hubbard’s Naval background which was totally contrary to every other document you found in his Naval records?

A Well, what comes to mind is the number of medals which are listed on this particular document, and it was a different number of medals. He was awarded four medals during the war. He has claimed to Scientologists two numbers, one being 28 medals and palms; one being 21 medals and palms, and this was a figure in between those amounts, in between 4 and 21, and gay recollection is that it also included a Purple Heart.

The Purple Heart later showed up in a color photograph of the medals which Mr. Hubbard claimed he had been awarded during the war.

Q And was it your belief that Mr. Hubbard had written this document?

A Yes.

Q Now with regard to exhibit 7-A, Mr. Armstrong, why did you send my office that document?

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A This document dated 4 March, 1967 which is a dispatch from LRH entitled "Saint Hill and OT Activities, Expenses," this document has to do with the original — the origins of the Sea organization, payment of Sea organization personnel then called the Sea Project and Mr. Hubbard’s paying these people at this time.

Q As their being employees of Mr. Hubbard?

A Yes.

Q And with regard to exhibit 7B through 7H, did you send me these materials to defend yourself, Mr. Armstrong?

A Yes.
Q And among those documents, was exhibit 7F written by Mr. Hubbard to be signed by a Tom Esterbrook?

A Yes.

Q And with regard to 7I, is 7I data on L. Ron Hubbard?

Did you send me 7I as more data on L. Ron Hubbard’s background, his claims about his background?

A Yes.

Q And, lastly, exhibit 7J; what did you send me 7J?

A This set of papers refers to Hubbard Explorational Company, OTS and this contains Mr. Hubbard’s handwriting in places and his initials. And it is signed by him. And it refers to transfer of monies from HEC, OTS, LRH, CFS.

Q And did you believe that necessary to prove as part of your defense that L. Ron Hubbard had been receiving monies from the Church of Scientology?

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A Yes.

Q Now, with respect to all the documents that have not been brought up, but are presently found under seal which have not been marked as exhibits in the 500 series, why did you send me those documents?

A The complete mass of documents which is what — whatever I was able to obtain from Hr. Garrison which he, for the most part, had duplicate copies of for the biography project, the mass of them together show a complete picture or, at least, a more complete picture than the exhibits which we took out of that mass of documents. All of them add to the overall picture regarding Mr. Hubbard and regarding his use of the organization, his control of the organization; the misrepresentations of his academic credentials and military career and so on.

The whole thing together gives a very complete picture of those facts.

Q Now, when Terry Gamboa told you to get a lawyer and you received the SP Declare, were you aware of the policy of L. Ron Hubbard regarding the use of the law set forth in the Level Zero Check Sheet?

A I was. I was aware of the way that Mr. Hubbard had used the law and ordered the organization to use the law.

I was aware that the law was used in order to attack individuals, in order for the purpose of harassment. So if that is what you mean, I was aware of that fact.

Q And was it your belief at the time that you

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retained me, Mr. Armstrong, that you were going to be attacked through the law by Mr. Hubbard’s organization?

A Yes.

Q And what, if anything, did you believe with regard to the scope of the litigation that Mr. Hubbard and his organization could subject you to?

A I didn’t know the scope in legal terms, but I knew they could bring incredible weight both legally and extra-legally against me.

Q And based on that belief did you send me as many documents as you felt you could obtain that you could use to defend yourself?

A Yes.

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Q Now, in your SP Declare you were accused on April 22, 1982 of:

"Being found to be promulgating false information about the church, its founder and members. He used his position to create and transmit erroneous information under the guise of documentation. Altered documents have been found in this area."

Was that of particular significance to you?

A What that signified to me was that the organization was carrying out what is called inside a "Black Propaganda Campaign" in order to discredit me, in order to discredit the statements which I made about Mr. Hubbard, about the organization. That was the significance that that had.

I saw that this document was being put out within the Scientology network and connected organizations internally, and that the purpose was to create an atmosphere into which it then became acceptable for further acts by the organization or by the intelligence operatives or as it turned out by private investigators against me.

Q Now, at that time were you familiar with the policy regarding Black Propanda written and copyrighted by Mr. Hubbard set forth in what has been referred to as the Green Books?

A Yes.

Q And again what are the "Green Books," Mr. Armstrong?

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A The Green Books are the public published policy, mostly written by Mr. Hubbard, having to do with
Scientology organization policy. They are statements of policy. They are policy letters which are supposed to govern Scientology organizations.

MR. FLYNN: May that be marked as the next exhibit in order, Your Honor?

THE COURT: Triple B.

MR. HARRIS: Which appears to contain a potpourri of items. It is collectively, I suppose.

THE COURT: Yes, collectively.

Q BY MR. FLYNN: Now, what did you understand the basic policy as set forth in exhibit triple B with
regard to Black Propaganda to be, Mr. Armstrong?

A That Black Propaganda was false statements from hidden sources designed to discredit and destroy
the reputation of the person who was being lied about.

Q And when you read the SP Declare with regard to altered documents and making false statements about
Mr. Hubbard, did you believe that to be part of the policy on Black Propaganda?

A Yes.

Q What if anything was your belief with regard to the necessity of procuring documents from Mr. Garrison to defend yourself against Black Propaganda?

A That it was necessary.

Q Now there was a statement on the Suppressive Person Declare dated April 22, 1982 of about your espousing

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the views of Timothy Leary?

A Yes.

Q Is there any truth in that allegation on the SP Declare, Mr. Armstrong?

A No.

Q And did you consider that to be Black Propaganda?

A Yes.

Q And what was your state of mind with regard to why that charge was made in the SP Declare?

A I saw a couple of possibilities, the first that is that it came out of whole cloth, that it was part of the Black PR campaign. It was to set up an atmosphere inside the organization so that people inside the organization did not believe me but felt that I had freaked out on LSD or that I had gone off the deep end.

The other thing was I had already been told by Laurel just a week or so prior to leaving that she knew of operations in which LSD was put in people’s toothpaste so there was another threat I felt from that quarter, and the other possibility was the planting of drugs on me.

Q Now at the time you left did you know or had you seen a declaration of an Ann Rosenbloom?

A Yes.

Q And did Miss Rosenbloom work in the Commodore Messenger’s org for Mr. Hubbard?

A Yes.

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Q And were you aware that drugs had been put in one of her drinks by a Joseph Lisa?

A I had seen that, I believe. I do not recall the specifics of it. I had heard that within the organization.

Q Now, do the use of drugs have particular significance to a Scientologist?

A Yes.

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Q In what sense?

A To a Scientologist who is not in the inner circle, at the top of the organization working directly with Mr. Hubbard, it is viewed that drugs are not to be used.

In fact, aspirin is not to be used. And one can’t be audited within a certain time of having even used aspirin.

Even medical drugs are frowned upon. And street drugs of any description, certainty, are frowned upon.

Q And, if any, bearing did that have in your mind with respect to the claim that you were associated with Timothy Leary?

A This was an effort to discredit me by connecting me up to LSD and Timothy Leary.

Q Now, in 1978-1979 when you were working with Mr. Hubbard at La Quinta and at Gilman Hot Springs did you have the opportunity to observe his behavior?

A Yes.

Q And what did you observe?

A During the period in which we were shooting movies in La Quinta and out in the desert and at various locations, I was able to observe him for long periods of time on a daily basis several hours a day. And my observation was that his behavior was highly irrational.

He yelled, in my opinion, without meaning. He raged at people. He swore a great deal. His language was atrocious.

I was definitely in fear because of the way that he raged at the slightest little thing on the movie set.

2077

His messengers — he was continually surrounded by messengers. And they acted the same way, yelling at people on the set, yelling at the various units for not performing their functions correctly. It was highly irrational.

Q Was he abusive?

A Yes.

Q And did he assign people to the rehabilitation project force for minor infractions?

A Yes.

Q Now, in the summer of 1983 did you become aware that Mr. Garrison had reached a settlement with Mr. Hubbard’s representatives?

A Yes.

Q And at that time what, if any, formal offer did you make to the plaintiff and the intervenor with regard to returning documents that are under seal?

MR. LITT: Are we — it is fine with me if he wants to go into settlement matters in this case. But I assume that is what is happening now?

MR. FLYNN: Your Honor, they offered the letters of Mr. Peterson with regard to making the demand for the return of the documents.

MR. LITT: It is an element of the case, Your Honor.

MR. FLYNN: It is our belief that the first time that –

MR. LITT: That is fine. Okay.

Q BY MR. FLYNN: What, if any, formal offer did you make for the return of the documents under seal, Mr. Armstrong?

2078

A What I went over with my attorney Bruce Bunch and my understanding that he relayed to Mr. Litt at that time was that we would deliver to Mr. Hubbard or his agents any of the materials which would not be needed for the defense of this case or the cross-complaint.

We requested that copies of any of the originals which we deemed were necessary for evidence would be provided to us and that the originals could be delivered to Mr. Hubbard.

Q Why did you send my office original documents?

A I guess because that is what I had. But I — my reasoning at the time was that original documents would be necessary in order to assist in the authentication of all of these materials.

Mr. Hubbard had been claiming since a long time — and I knew of his letter from 1953 or 1977 to Mr. Garrison which ultimately made its way to Mr. Garrison in which he claimed that his records had been stolen in 1953 and that the government had been putting forged or altered documents into his dossier.

I had heard this a number of times just prior to leaving.

A man by the name of Harvey Haber, who was an organization person then in charge of selling Mr. Hubbard’s fiction work, "Man, The Endangered Species," which later was renamed "Battle Field Earth," he at that time had or had seen, but in any case, had in his hands at one time just prior to that, somewhere around December, 1981 –

2079

MR. LITT: Is that what Mr. Haber told Mr. Armstrong?

THE WITNESS: That is correct.

MR. HARRIS: There will be an objection; hearsay unless it is for again –

THE COURT: Well, it is his state of mind. Had to do with the originals.

THE WITNESS: That Mr. Hubbard had stated that he had heard that there was some questions regarding statements he had made about his past, and he stated, and this was relayed to me by Mr. Haber that he wanted everyone to know that this dispatch had gone from Mr. Hubbard to David Miscavige.

Anyway he wanted everyone to know that everything Mr. Hubbard had said about himself and everything that the PR’s had said about him was, in fact, true, and I had a great deal of concern that the organization might come out and say that all these documents are forgeries because if they were copies, I certainly was not going to have their assistance in the authentication of these documents. This is a claim which has been made before and I was concerned about it.

So, I had originals and rather than copy them all at expense which I couldn’t afford, and because I felt that we would run into an authentication problem or perhaps that these were all FBI created documents, I elected to send you originals.

Q BY MR. FLYNN: And, in fact, in your SP Declare you were accused of alteration of documents; is that correct?

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A That is correct.

Q Now, has it been your belief and understanding, Mr. Armstrong, throughout this litigation that the Church of Scientology has had copies of all documents under seal or Mr. Hubbard’s representatives?

A My belief is that they have copies of virtually/all of it, copies in one form or another.

Q And what is the basis for that belief?

A Because of the nature of the documents which are herein because of the place from which they had come, because of the subject matter, because of the organization’s interest in these things, and because of the — those are areas in which documentation would have been collected by B-1 in order to handle the questions which continually come up in these areas.

Q Now in your deposition you were asked about the source of originals from two areas in which you said you didn’t believe that there were copies left in those two sources; you recall that testimony?

A Whether or not I had left materials in archives?

Q Correct.

Q Now when you answered that question, was it your belief at the time that there were copies in other areas other than the two that you were questioned about?

A My belief is that for at least the vast majority of the originals which are under seal there are copies, either copies of the letters, copies of the documents

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under seal or within the organization, either at GOWW, GOUS, my archives, Controller archives. Some of them were went to Mr. Garrison. So, my belief is that the vast majority of them, I have no way of confirming that, but knowing the contents and knowing the location from which they came, that is my belief.

MR. LITT: Just a moment. Is this being introduced for his state of mind as to why he sent originals because if it is introduced for fact, it is not fact and his opinion without fact as to whether there are things in the archives to establish that there are such things in the archives is improper because there is no foundation for that.

THE COURT: Well there is no way for him apparently to go check the archives, and I will overrule your objection. He can give his opinion on that subject. The weight to be given to it is something else again.

Q BY MR. FLYNN: Now, do you feel, Mr. Armstrong, it is necessary to have possession of copies of the documents that are under seal for purposes of prosecuting your cross-complaint?

A Yes.

Q While you were collecting the documents, did you have conversations with Laurel Sullivan regarding inurement to Mr. Hubbard in connection with your services as an employee of Mr. Hubbard’s?

MR. LITT: Objection. This is going back directly into MCCS, Your Honor.

2082

THE COURT: I don’t know whether it is or it isn’t.

MR. LITT: But we have to establish that before he answers the question and goes into attorney-client privileged areas. Apparently from the –

2083

MR. FLYNN: It has nothing to do with MCCS, Your Honor.

MR. LITT: May I finish, please, Mr. Flynn? And then you can speak.

Thank you.

Your Honor, I think there should be an inquiry whether or not anything about "inurement," was placed upon consultation with attorneys concerning various tax matters.

I think the court will find that whatever Miss Sullivan said was as a result of consultation with attorneys and plans that were being developed in relationship thereto.

I think that it is appropriate for there to be that preliminary inquiry before this simple question is asked under these circumstances.

MR. HARRIS: Also, Your Honor, I understood that Mr. Flynn was going to put Miss Sullivan on the stand and then he would recall him in respect to those items.

MR. FLYNN: This has to do with the biography project, Your Honor, and his understanding with regard to during the biography project he had to be an employee of Mr. Hubbard because if he wasn’t an employee of Mr. Hubbard, it would have been inurement to Mr. Hubbard if he was an employee of the church and a violation of the Internal Revenue laws.

MR. LITT: And presumably some lawyer who might be right, might be wrong and some lawyer whose advice may have been followed or may not have been followed, if that is –

THE COURT: We’ll receive it to show his state of mind on the subject.

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The objection is overruled.

Q BY MR. FLYNN: What was your understanding, aside from any conversations with any lawyers, Mr. Armstrong, with regard to who you worked for and why when you were doing the biography project?

A That was at that time inurement which was a subject which was discussed between Laurel and myself a great number of times. And in those conversations, it — what was discussed and the conclusion was reached was that because I was involved in a project directly working for Mr. Hubbard for which he would make a great deal of money, I had to be paid by Mr. Hubbard and could not be a part of the organization; otherwise, the inurement charge would follow.

MR. FLYNN: Your Honor, that is all I have on direct with the one proviso we had previously discussed about Laurel Sullivan.

I have an exhibit coming that I would like to put into evidence that is the book that Mr. Armstrong mentioned, "The Science of Survival" that is dedicated to the daughter of L. Ron Hubbard, Alexis Valerie. I don’t have the book at the present time. I am supposed to receive it at 1:30.

THE COURT: We’ll worry about that later, then.

You may cross-examine, Mr. Litt.

MR. LITT: Well, actually we are both in the course of time going to cross-examine, but on different subject matters.

THE COURT: All right.

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CROSS-EXAMINATION BY MR. LITT:

Q Mr. Armstrong, when you left the church on December 12, 1981, aside from archives materials, what materials did you take with you?

MR. FLYNN: Your Honor, at this point it is my understanding that the defense or the plaintiff and the intervenor, having in their case read excerpted portions of Mr. Armstrong’s deposition, are precluded from re-examining in areas that constitute the areas which have been read into the record from excerpted portions of the deposition.

This question was specifically asked and answered in the excerpted portions of the deposition.

THE COURT: I am not any more anxious than anybody else to have a lot of repetitive testimony. But on the other hand, I don’t know if there is anything that precludes the cross-examination unless it is cumulative or unnecessarily repetitive.

At this point I would overrule the objection.

MR. FLYNN: Would you just note my objection to any area which is repetitive to what has already been read as the record subsequently shows?

THE COURT: I’ll deem that you are making it. I have no way, of recalling at this point what has been read and what hasn’t.

Let’s go forward anyway. We are past square one.

Do you remember the question?

THE WITNESS: Yes. Your Honor.

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THE COURT: You may answer it.

THE WITNESS: Here, on the final day when I finally left –

Q BY MR. LITT: Let me clarify my question.

My question isn’t what you took out on that day, but up until that day; in other words, through December 12 what material other than archives material had you taken from church files or copies thereof?

MR. FLYNN: Your Honor, again, I don’t intend to keep on objecting.

THE COURT: Why are you doing it, then?

MR. FLYNN: Church files; we believe they are L. Ron Hubbard files. If it could be understood that church files mean L. Ron Hubbard files, I won’t object. But the statement of Mr. Wertheimer in his letter that all of these documents are in the ownership and possession of L. Ron Hubbard, we believe is pretty conclusive evidence that that was the case at the time.

THE COURT: For whatever it is worth, the church is taking the position that they were the bailee of these particular documents. And the question is being asked in that context. So rather than get into any discussion over who was the owner, we’ll take it in that context.

You may answer.

THE WITNESS: The documents which I had which were in addition to archives documents which I viewed were my documents were copies of any financial transactions or, at least,

2087

whatever I had from as long as I had been involved or as long as I had been collecting those records.

I had copies of pay vouchers; I had copies of accounting which I had done for all the projects going back, I believe, as far back as the ship, but perhaps not that far back.

In any case, those were what I took.

And in addition to any archives material which I have provided to Mr. Garrison, I had transparencies of slides which I took when I left the organization.

I spoke to Barbara DeCelle right around that time, the day following when I was driving out and let her know that I had these and why I had them; that I still had some work to do with them.

I took my personal letters, but those were my personal letters.

Q What personal letters?

A Personal letters which I had in the organization.

Q Did they have to do with Scientology matters?

A No.

Q Why don’t you — I’ut not asking you for the contents, but can you elaborate on what you are referring to when you are referring to personal letters?

A I keep in the archives area a file which contained all of my correspondence with my family. It was just a file.

There were probably two or three, various family members involved. And I took all of that stuff out.

I took out copies of it when I did the final

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accounting.

I took a copy of the letter which I sent to Barbara DeCelle at the — the day that I left and copies of the checks which I sent turning in the balance of any funds which I had for the biography project.

I sent one check to Mr. Hubbard via LRH accounts, Jim Isaacson. And I retained copies of that correspondence and the checks.

I think that is what comes to mind at this time.

Q BY MR. LITT: Did you take any correspondence or other materials that are not archives documents themselves?

Do you know what I mean when I say archives documents? Just to make sure we have our terms straight,
I mean documents that are being collected for archives as opposed to any correspondence that might have related to them, but are not archives materials themselves.

A Okay. I understand.

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Q Did you take any correspondence or other materials not archive documents relating to your activities in connection with the archives project or related matters over the previous two years?

A I believe only what I have told you about.

There were copies of financial records.

Q Well, you don’t have to repeat it.

A Okay. My best recollection is just what I have told you.

Q Now so have you now described for me everything that you took when you left, aside from archive documents?

A When I left I took –

Q Up to when you left.

A Do you mean specifically from files, not my personal materials, not my clothes?

Q Right.

A Are you asking a broader question that you originally did?

Q I am not asking a broader question. I just want to make sure that I have a full answer to that.

A I believe what I have told you is everything other than archival materials that I took during the period when I was leaving the organization.

Q All right. Now, have you written any letters since — well, let me take starting with the period 1980, have you written any letters other than within Scientology channels — can I use that phrase? Do you know what I mean/when I use that phrase?

2090

A Okay.

Q Did you understand it because if not, we will get it cleared up.

A Yes.

Q Other than within Scientology channels starting with the period 1980, did you write any letters or have any correspondence with anyone on the subject of Scientology and your attitude toward Scientology, and I will take that for 1980 through 1982.

A Other than Scientology channels?

Q Right.

Q Okay. There is one that comes to mind, and that was a letter to a man by the name of Perry Chapdelaine who was an early Dianeticist and he lived somewhere in Tennessee. I don’t recall the city, somewhere near Nashville, I believe, and I wrote to him on some of my feelings at that point about Scientology or about Scientology practices.

In 1982 I wrote to Laurel Sullivan, to Dick Sullivan. I don’t recall if there was anyone else during that period specifically on Scientology. It is possible, but that is what comes to mind.

Q Did you have any correspondence with any family members on that topic?

A It would have been a very small amount in which it would have been mentioned. I don’t know, not a great deal.

Q Do you have copies of your correspondence

2091

to Perry Chapdelaine, Laurel Sullivan and Dick Sullivan?

A No. The letter — there were a number of letters to Perry Chapdeline in the period of 1980, ‘81, at least one which I mentioned some of my feelings about some of the Scientology practices. That would have been left in the organization in the archive area when I left. Correspondence with Laurel or Dick Sullivan, I don’t have those.

Q All right. Now you mentioned in your direct testimony that you at some point began keeping a record, and I wasn’t sure how frequent this record was, of your experiences, I guess it was with what you called harassment; am I right about that?

A Yes.

Q When did you begin keeping that record?

A My recollection is it is some time in August, mid-August 1982.

Q And up until what period of tine did it go?

A Up to I believe somewhere in September, perhaps up to September 20, September 22. That would be the date on which I last perceived one of the private investigators tailing or shadowing me.

Q And was the purpose of this record to record while matters were fresh in your mind what had transpired on a particular day or a particular occasion?

2092

A Well, that was part of it. I felt that I was at that time the object of an incredible campaign. And I wanted to document the facts.

Q And so you wrote down everything that occurred on a daily basis with respect to the subject of Scientology or what you felt was related to that topic?

A I wrote down incidents regarding the private investigators at that time, not necessarily my thoughts regarding Scientology, but this is — it is a fairly detailed description on a daily basis of what I viewed incidents of harassment.

Q Okay. Now, aside from that document — which I’ll come back to — from the time that you left Scientology on December 12, have you kept on records or notes other than this record of private investigators, journals or diaries in which the topic of Scientology or your attitudes towards Scientology is mentioned?

A At some point in the summer of 1982, summer or spring of 1962 I wrote what was a chronology which brought me up to my beginning in Scientology through 19 — probably 1974. I was still on the ship. So I had that. I think it amounted to maybe 20 or 30 pages typewritten. Other than that, other than writings which are not a documentation of any facts, there is nothing.

I do write notes to myself. These are more introspective notes, sort of trying to determine what happened and what happened to me mentally through those years.

I don’t know if that is what you are seeking,

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but those are the only other notes or records. And they are not a documentation of events that were going on on that day, but rather a mental documentation. Those are the only things that I have or did.

Q Are these notes that you have referred to collected in a particular — are they kept together in a file, or do you maintain them?

A Well, I have a number of them. They are a pretty big mass and not all of they refer to Scientology. But there are references to Scientology and references to Mr. Hubbard. But they are just my personal notes. And, yes, I do maintain them.

They are not particularly well organized, but they take up, I guess, about six inches in depth.

Q And did you begin engaging in this practice from the time you left?

A No, it began, I suppose sometime after the harassment that went on — that was a pretty intense period. And it just began right after that.

Q Have you ever written anything for publication or for possible publication that referred to either directly or sort of by the use of different names, but in reality was a reference to your experience in Scientology?

MR. FLYNN: Does this include communications with counsel, Your Honor?

MR. LITT: None of my inquiries include communications with counsel.

THE WITNESS: There was a thing which I wrote, I guess,

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in 1982. And it would have been in May of 1982. And I never completed it. It was — it dealt mainly with the paranoia that I was going through at that time and my behavior at that time.

I was walking around in the middle of the night with a knife and peering out of the windows and that sort of thing. And the terror that was in my mind at that time. And I gave — I’m sorry –

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Q Do you still have a copy of that?

A I believe I do.

MR. LITT: Your Honor, we would ask that we have produced for us the following materials:

One, the record of — the court should understand, as we have said before, that on the matters that we are dealing with here this case was not prepared on that basis, so there are some materials that might otherwise have been obtained that weren’t obtained, but given the nature of Mr. Armstrong’s testimony, I think it is reasonable that we obtain it at this point.

We would like the record made by Mr. Armstrong of his experiences with the private investigators.

We would like his chronology of the positions and other things that he’s held in Scientology. I think he said from joining until 1974.

We would like, and it is perfectly agreeable with us that the court review first to pull out, only the portions that are relevant because I am not interested in having private materials of Mr. Armstrong on other subjects, but these notes that he’s written that reflect his attitudes and feelings about Scientology or Mr. Hubbard.

We would like that and we would like a copy of this draft that he wrote in May of 1982 which dealt with his mental state at that time and I guess sort of a fictional work. I am not completely clear.

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MR. FLYNN: Your Honor, my reaction is that we have no problem producing any of it with the one caveat that I’d like to examine it, and barring any attorney-client privilege — I know that Mr. Armstrong sent me a recitation of the chronology of his history in Scientology some time during the summer of 1982. I am not sure whether that is the second or mot, but my reaction is we have no problem.

THE COURT: All right. Well we will take a recess until 1:30.

(The noon recess was taken until 1:30 p.m. of the same day.)

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Los Angeles, California; Wednesday, May 16, 1984; 1:30 p.m.

—0—

THE COURT: In the case on trial, let the record reflect that counsel; the witness has retaken the stand.

State your name again for the record, sir. You are still under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: Very well. You may continue, Mr. Litt.

GERALD ARMSTRONG, resumed the stand, having been previously sworn, testified further as follows:

CROSS-EXAMINATION (Resumed) BY MR. LITT:

Q Mr. Armstrong, when we left off this morning we were talking about the variety of materials that you might have in your possession. Let me just clear up one thing.

If I understand your testimony correctly, when you left your post, other than archives materials that you gave to Omar Garrison, you didn’t have copies of any file materials pertaining to the archives projects activities; is that correct, internal correspondence, anything like that?

A Correct. Other than what I have told you about.

Q Well, maybe you can explain something for me; there have been a series of exhibits that have been marked in this case that so far as I can determine were not produced

2098

in discovery by the church. And I’m interested in knowing where some of those materials — how they came into your possession; for instance, there is exhibit DD, the Dive Bomber dispatch; where is that from?

A I obtained a copy of the Dive Bomber dispatch during the beginning of my work on the biography project. And that was in February, 1980.

I subsequently gave it to Mr. Garrison.

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Q And then did Mr. Garrison give it to you?

A Yes.

Q When was that?

A It would have been some time in 1982.

MR. FLYNN: I believe that document is under seal and was marked as an exhibit under seal.

MR. LITT: Well I may be incorrect about that. Let me check.

MR. FLYNN: It is E under seal.

MR. LITT: Okay.

Q There is some correspondence that was marked as an exhibit by you, and I believe and you can correct me if I am wrong, that they are not under seal. For instance, there is exhibit GG, which is a letter to Alan Wertheimer from Larry Brennan of January 2, 1981; exhibit FF — I may have the date wrong on that — exhibit FF is a letter from Alan Wertheimer to Larry Brennan of December 2, 1981; exhibit EE is a letter from Alan Wertheimer to Larry Brennan of November 17, 1980.

Where did those come from?

A Originally I obtained them from Laurel while working on the biography project. Subsequently I gave them to Omar Garrison, and a year or many months later I obtained them from Mr. Garrison after this lawsuit began.

Q So after the lawsuit began and after you had been ordered to turn over all materials in the archives you then went and obtained materials from Mr. Garrison

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that you had provided to him in your capacity as archivist; is that right?

A At that point they were attached as exhibits to a declaration which was filed.

Q By whom?

A By me in this case some time in — be September 1982.

Q All right. So you had to prepare a declaration to be filed in September 1982; is that correct?

A That is correct.

Q And this was after the temporary restraining order required you to return all the archives materials had been entered; is that correct, August 24th?

A I believe all the archives materials had been, but I think that that is correct.

Q And then after that order had been entered, you went and obtained from Mr. Garrison additional materials that had been provided to him in your capacity as archivist; is that correct?

A To the best of ay recollection, I believe so.

Q And let’s go through some of the others.

Is that when you obtained a copy of the contract between Mr. Garrison and PUBS DK?

A It is — I don’t know if I obtained that at that point or not. I believe my recollection is here that I had already sent that or shown it to Mr, Flynn, but it is also possible that at that time I obtained it from Mr. Garrison.

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Q And the letter that you have testified to addressed to C — Controller of 15 October, 1980; is that something you had given Mr. Garrison?

MR. FLYNN: What exhibit?

MR. LITT: That is exhibit J.

THE WITNESS: What is the date of that?

Q BY MR. LITT: October 15, 1980 is the letter to the Controller.

A I am not sure. My recollection is that that was produced at a deposition. That is my recollection, but it could be — I really don’t know on that one.

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Q Okay.

A My recollection is that the organization produced it at a deposition or used it in some way in connection with this lawsuit.

Q And exhibit HH which is a letter from you addressed to Gale, where did you get that from?

A Mr. Garrison.

Q So that is something you had given Mr. Garrison in your capacity as an archivist?

A Yes.

Q And in September of 1982 you went back and got that from him also?

A I don’t know if I got it at that time or earlier, but in any case, I got it from him. I had given him that thing because we had a great deal of concern at that point about Jocelyn’s or my being locked up. And I gave it to him, a copy of it.

And sometime later I asked him to see if he could locate it. And he did. And he gave it to me.

Q Exhibit II, which is a letter from you to Cirrus of November 25th, 1981, did you get that from Mr. Garrison also?

A I believe so.

Q And that was in September, ‘82?

A It possibly is around the time of the lawsuit at which point I had to obtain documents relating directly to that subject.

MR. LITT: I’m going to move to strike the last portion

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of the answer.

THE COURT: All right. it will be stricken.

Q BY MR. LITT: Exhibit JJ, a document of November 18, 1981, which is a communication from Vaughn Young
concerning the biography debug, did you get that from Mr. Garrison?

A I got that from Mr, Garrison, but it was a lot later.

Q When was that?

A Sometime in 1983.

Q And you went back to Mr. Garrison in 1983 and you asked him to give you documents that you had given to him while you were in the archives post?

A Basically, yes.

Q And exhibit AA which is your nonexistence letter of February 3rd, 1980, did you get a copy of that from Mr. Garrison at some point?

A Who is that document to?

Q That is the one, if I remember correctly, that doesn’t have a name on it. It just says to blank. And from Senior PPRO Research.

A I believe you produced this document in this trial.

Q That is correct, But did you get a copy of that by some other means from Mr. Garrison as well?

A I am not following you.

Q My question is aside from the fact that it was produced by the church, at some point did you go to

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Mr. Garrison and get a copy of it prior to that?

A No, I don’t — well, I don’t believe he had a copy. I don’t — I — I am a bit confused. Are there two copies? Are there two such documents?

Q Are there two such documents? Well, once you have a Xerox machine, there can be an endless number of documents.

A The only — the first time I recall seeing it is when it was produced by you in this trial. That is the first time since l980 or ‘81.

Q Exhibit KK, which is a handwritten note from Vaughn to Sue of November 28, 1981, is that another document that you went to Mr. Garrison to obtain?

A Yes.

Q And that document also you had given to him while you were archivist?

A Yes.

Q And exhibit LL, which is a November 28, 1981, document from Vaughn Young, did you obtain that from Mr. Garrison as well?

A Yes.

Q And exhibit TT, which is an October 30th, l981 draft of a document, did you get that from Mr. Garrison as well?

A Could you describe the document in a little more detail?

Q it is — let me just double check it here.

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It is a document dated October 30th, 1981.

At the top it says "CO LRH ED." But it is not an issue; formerly presumably somebody’s draft. And it says "Project biography debug personnel Vaughn Young, IC."

Did you go back to Mr. Garrison and get that from him?

A Yes.

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Q Now, many of these materials that we have been discussing here were not materials addressed to Mr. Garrison; is that correct?

A That is correct.

Q They were materials that you had given him because you thought he should be aware of them given the fact that he was working on a biography pursuant to the contract with PUBS DK?

A That is at least part of the reason. That is the underlying reason.

Q Is there some other reason?

A Mr. Garrison was at that time attempting to renegotiate his contract. We had become aware of the fraudulent basis for the contract. Some of the clauses which he had agreed to he was enticed into by fraudulent representations.

MR. LITT: Your Honor, I am going to move to strike all of that as a conclusion.

THE COURT: All right. I will strike it.

Q BY MR. LITT: In addition to giving it to him in your capacity as an archivist, you gave it to him for purposes of his renegotiating the contract with PUBS DK; is that correct?

A I gave it to him to inform him of what was being done.

Q So you felt that in your opinion there were things being done that weren’t right; is that correct?

A There had been things which had been done

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which were not right.

Q Okay. So you made the decision on your own that there were certain internal church material that he should see; is that correct?

A Yes.

Q And so you gave it to him; is that correct?

A Yes.

Q That is why you were acting as archivist?

A Yes.

Q Did you check with any senior about doing that?

A On some of those. My recollection is that Laurel knew about the Wertheimer letters, but the others I don’t believe I checked with anyone.

Q Now there are also some biography sketches that were produced or used by you. Did you get those from Mr. Garrison, also?

MR. FLYNN: Can we have a little more specificity, Your Honor?

THE COURT: Sustained.

Q BY MR. LITT: Exhibit S, I believe, but I am not absolutely positive on that — no, no.

Q That was a magazine; is that correct?

MR. FLYNN: Are you talking about the magazines such as "Successes in Scientology," "PRO"?

MR. LITT: No. That is not what I am talking about.

Q Exhibit H is a document entitled "A Brief Biography of L, Ron Hubbard" and at the top it says

2108

"Originally Printed Circa 1960."

MR. FLYNN: That is a sealed document, Your Honor, which is identical to — that is a sealed document which is a copy which is identical to exhibit S, I believe.

MR. LITT: Your Honor, Mr. Armstrong can answer the question. I as trying to get some things straight.

THE COURT: Well, of course, the witness doesn’t have any cross reference to what the exhibit is, but let’s go ahead.

Q BY MR. LITT: Are there any other materials that you obtained from Mr. Garrison after the TRO was entered in this case that you had given to him in your capacity as archivist?

A There way be others. If there are, they have been produced at one deposition or another to the best of my knowledge.

Q Now, Mr. Armstrong, do you have in your possession a set of Orders of the Day from the Apollo?

A No. I can clarify –

Q Have you had at some point?

That is all right. I will ask the questions, Mr. Armstrong.

Have you had such a set in your possession at one time?

A I have not a complete set but a partial set from the period approximately 1970 to 1974.

2109

Q Is it complete for that period of time?

A No.

Q But you don’t presently have those in your possession?

A No.

Q Where are they?

MR. FLYNN: Your Honor, this, I believe, is a set that belongs to one of my contacts whose identity the person seeks to preserve, if you’re talking about the same set.

THE COURT: Well, where did you get it from?

THE WITNESS: I got it from someone named Jim Dincalci.

MR. FLYNN: Okay. that is a second set.

Q BY MR. LITT: When did Mr. Dincalci give these to you?

A I would think somewhere probably in early 1983.

Q Did you ask them for them, or did he volunteer them to you, or what?

A He mentioned that he had had them. and my best recollection is that he said did I want them.

I said yes and I took them.

MR. LITT: May I have one moment, Your Honor?

THE COURT: Yes.

Q BY MR. LITT: What about any other materials?

You didn’t take anything from your personnel or student files when you left; is that correct?

A That is correct.

Q Have we covered everything now that you obtained from Mr. Garrison?

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A I am not sure how to answer that question.

Q Well, in terms of anything having to do with the biography or materials provided to him in connection with his biography work that you subsequently obtained from him other than archives materials themselves?

A I believe no.

Q Now, with respect to the orders of the day, Mr. Armstrong, that we were discussing before, you said that Mr. Dincalci had given you the set from 1970 to 1975: is that correct?

A I think I said ‘ 74. It may be ‘74 or ‘75. And I can’t tell you the date that it starts or ends or even what percentage of the total orders of the day are comprised.

Q Do you remember being asked in interrogatories in this case regarding a set of documents known as orders of the day from the Apollo for the period of 1970 to 1975, "Please state, A, where you obtained these documents and, B, the date that the documents were obtained by you"?

A I don’t recall the specific question, but it is very likely.

Q The document entitled "Interrogatories propounded to defendant Armstrong by intervenor Mary Sue Hubbard and plaintiff Church of Scientology of California" at page 25; the document has a proof of service of the December 14, 1983.

Can you take a look at that, Mr. Armstrong, and tell me if that refreshes your recollection?

A Okay.

Q Does that refresh your recollection? Do you

2111

remember that document?

A I do recall the question which I have now looked at.

Q Showing you a set of what is entitled "Further responses of defendant Gerald Armstrong to interrogatories propounded by intervenor Mary Sue Hubbard and plaintiff Church of Scientology of California," do you recognize your signature there as verifying the responses executed on March 5, 1984?

A Yes.

2112

Q All right, and here next to the question No. 150, the answer to A which is where you obtained these documents, referring to Order of the Day is, "on the Apollo"; is that correct?

A Yes.

Q And the answer to B, the date that these documents were obtained by you is, "1971 to 1975?; is that correct?

A Okay.

Q Is that correct?

A Which?

Q 1971 to 1975 for B.

A Yes.

Q Did you prepare those answers?

A I believe so.

Q Were they correct at the time?

A Yes.

Q Are they correct now?

A Yes.

Q I thought you had just told us that you obtained your copies of the Orders of the Day from Jim Dincalci?

A Well those ones, and I did not have, I believe, the Van Schaick deposition with me, and I had seen virtually every order of the day published between 1971 and 1975 because I was on the ship at the time, so I obtained each one of those documents at that time, and that is what I was referring to when I wrote that.

2113

Q That is what you were referring to when you wrote the answer?

A That is correct. If you are talking about specific ones which I did not recall from Van Schaick, I believe I would have said in the Van Schaick deposition that I had seen all these documents prior to when I was on board the ship. They were not new documents to me, and I also think in Van Schaick that I laid out the obtaining of the documents at both times.

Q So, let’s get this clear.

You had Orders of the Day when you were on the Apollo?

A Yes.

Q And you claim you no longer have those?

A That is correct.

Q But you got another set from Jim Dincalci?

A Not a complete set, but at least a partial set from ‘70 through ‘74.

Q Okay. All right, now, let me ask you some questions about materials that you have read in the course of your years in Scientology.

What do you recall reading in the year 1969 on the subject of Scientology?

A "Dianetics, The Modern Science of Mental Health," "Science of Survival," "Problems of Work," "New Slant on Life," book on Scientology ethics.

Q Was that the title or did it have a title?

A It may be "Introduction to Scientology Ethics."

2114

There were several magazines or pamphlets from that period from 1969, the titles of which I don’t recall, but there was a great number of them. Part of "8-8008?,"8-80," some of the "Credibility of Human Ability," Phoenix lectures.

Those are what I recall.

Q All right. That was in the year 1969; is that right?

Q And do you recall what you read in 1970?

A More of the same materials; "History of Man," "8-8008," "8-80."

A You studied those materials further?

A Yes. I also did during that period a pack of materials called "The Hubbard Standard Dianetics Course."

I did the pack of materials of "Policies Dealing with Scientology Finances."

Those are what I recall.

Q So far you have listed books and you said there were several publications in 1969 and 1970; do you remember any of them?

THE COURT: He’s just listed a bunch of books.

MR. LITT: I am sorry.

Q I mean periodical-type publications as opposed to books.

A There were a number from that period. There was one called "Success." I believe there is one entitled "Scientology."

The early editions of "Advance." I don’t

2115

know if those were in ‘69 or ‘70, but definitely the "Advance" magazine in that period.

There were promotional pieces put out on the Sea Organization. There may have been other magazines, the titles of which I don’t recall right now.

2116

Q What kind of promotional materials on the Sea organization?

A Promotional materials –

Q Can you identify them in any way?

A I believe I have produced one here in this trial. But there were other ones as well which showed pictures of the ship and they were recruiting promotional pieces.

Q All right. Now, in 1971 was the year you joined the ship; is that right?

A Yes.

Q And do you recall what materials on the subject of Scientology you read in that year?

A There was an initial course which I did called the Check Out Mini Course.

Q Let’s leave courses alone for the moment. How about books first?

A I don’t believe I — not that I recall anyway, any particular book from that period. There were mostly course packs, materials assembled into packs.

Q All right. Let’s take your years on the ship, Mr. Armstrong; first, again addressing ourselves to books, what books did you read in addition to what you have already stated while you were on board ship in that time period; in other words, 1971 to 1975?

A I read at least pieces of a book called Dianetics Today.

I read The Ship’s Org Book.

I read pieces of the Scientology Dictionary.

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I read a book called Volume Zero.

I read pieces from the other volumes of the OEC Course. That is principally it that I can recall at this time — oh, I’m sorry. I also read A Spy and His Masters and The Art of War. And I think there was another one called Total Espionage.

Q What about periodicals?

A I read the O0DS which came out every day.

I read Advance Magazine.

I read –

Q Did you read that regularly? Was that published on some kind of regular basis?

A Yes. It was, I believe, monthly, maybe bi-monthly, publication. In any case, it came out regularly while we were on board.

I read the policies and technical bulletins as they were published on board.

I read the PRO publication. I don’t recall its name. I think it changed from PRO News. But it was something similar. And that was put out as a newsletter during a period of time on board. That is what I recall.

Q Okay. Now, during that period did you read any materials that were designed to sort of introduce Scientology to others; for instance, some of these I am not that familiar with. So I may have my dates wrong. But, for instance, the Basic Scientology Picture Book or What is Scientology, books like that; did you read any of those, or were you familiar with them?

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A What is Scientology, I believe, was published in 1978. So we wouldn’t have had that on board.

I do recall The Picture book. I don’t believe I — my perception of it was that it vas an introductory thing to get people into Scientology. And I did not look at it in depth.

2119

Q And what other introductory things like "Scientology A New Religion Emerges in This Space Age"?

A I saw that during that time as well.

Q And were you familiar with it at all?

A To some degree. I had sent a copy to my parents, I think to a Member of Parliament, so I was to some degree familiar with it.

Q All right, now, let’s take the period of leaving the ship. Other books and periodicals that you read?

A Part of "What is Scientology?" Part of the "Volunteer Minister’s Handbook."

Those are the only later books that I recall reading. There may be more and I continually looked back over the earlier books. Somewhere along the line I read "Dianetics, The Original Thesis," "All About Radiation." That is one of the earlier books I read.

"E Meter," "How to Operate the Emeter," "E Meter Essentials" and these would have been after the ship.

I would have read those in the RPF.

Q You read books about the E Meter when you were in the RPF?

A Yes.

Q The E Meter being what is used in the course of auditing by an auditor, this machine that you called having electrodes?

A Yes.

Q What about tapes, did you listen to tapes

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of Mr. Hubbard?

A Yes.

Q What was the first tape that you recall?

A The first one was given at a lecture, a public lecture in Vancouver and I really don’t recall the name of it.

Then I did a set of tapes: called the "Study Tapes," I listened to the study tapes. It would have been in 1969/1970. On board the ship I listened to — actually I listened to some more tapes on board the Bollivar in the beginning of February 1971 called the "Welcome to the Sea Org" series.

Then I listened to a number of tapes, particularly on the RPF. There were several tapes which I listened to having to do with auditing. Those are what I recall right now.

I listened to a number of the "Philadelphia Doctorate" tapes, and "The Story of Dianetics and Scientology," "Ron’s Journal 67."

Q When was this that you heard these? Was this all on the ship?

A I think I heard "Ron’s Journal 67? in Vancouver, but I also heard it on the ship and "Story of Dianetics and Scientology" that would have been perhaps 1979 or ‘80.

Q The "Philadelphia Doctorate" tapes when was that?

A I heard some of those very early on in Scientology, but I listened to several of them in 1980 and ‘81 while doing the biography work.

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Q Now, Mr. Armstrong, you have spent quite some time testifying. And I want to review some things just so I understand what it is.

You are saying — you have claimed that there are certain misrepresentations that are shown by these documents. And I would like to see if I can get an understanding of, in a general way, what the purported misrepresentations are.

As I understood it, you claim that there are misrepresentations concerning Mr. Hubbard’s war record; is that correct?

A Yes.

Q All right. and you claim that those misrepresentations include representations about medals that were received; is that right?

A Yes.

Q And does it also include representations about how many theatres of war that he was in?

A Yes.

Q And does it also include representations concerning an incident with some submarines or something like that?

I am just trying to understand what it is you are saying. I hear a lot of different things from Mr. Flynn and whatever. So I’m trying to find out from you exactly what it is.

MR. FLYNN: There is a list that has been marked as an exhibit.

THE COURT: He has a right to cross-examine. We don’t

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need editorial comments.

Let’s go forward.

THE WITNESS: The alleged incident with the submarines, I am not certain about.

Q BY MR. LITT: Okay. So, so far in the war I have these two things; what is it you contend with respect to Mr. Hubbard’s war record that constitutes misrepresentations?

A He was not a commander of a squadron of corvettes; he did not — was not cripled and blinded in the war; he was not the first casualty of the Far East; he was not flown home in the Secretary of the Navy’s private plane; he was not replaced by 15 officers of rank at the beginning of the war.

Those are what comes to mind right now.

Q Does that cover the war record that you claim?

A I can perhaps continue on.

The final result is that he is not –

Q I are not asking you for the final result. I am asking you for what it is you claim are misrepresentations concerning Mr. Hubbard’s war record.

Is there anything else that you claim has been represented that in your opinion is wrong, concerning his war record?

A There are at least these. There may be more.

Those are what I recall right now.

Q Those are the ones that you consider at least significant? Would that be a fair statement?

A I think — well, what I consider of significance is the overall picture of it.

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Q So it is not a question of whether or another particular thing is inaccurate, but it is, in your view, the fact that when taken as a whole, there is a wrong picture given?

A There is the quantity which adds to a whole.

Q Now, what about Mr. Hubbard’s youth or teenage years; I think you made some reference in the course of your testimony about his travels in the Near East; what is it that you claim constitutes misrepresentations about Mr. Hubbard’s travels in Asia?

A His claim of studying for several years, from 1924 to 1929 in the Far East; his having been in India, having studied in China under Llama priests; his being in Mongolia wandering through the Far East for years, those sorts of things.

Q Are those the main ones?

A My recollection right now, yes.

Q All right. Then I understand that you claim that there are misrepresentations about Mr. Hubbard’s credentials?

A Yes.

Q And those have to do with either academic credentials or things that he has done; is that correct?

A Yes.

Q Let’s take the academic credentials; what do you claim has been misrepresented concerning Mr. Hubbard’s academic credentials?

A That he graduated from George Washington University; that he is a member of the first course in the

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U.S. in atomic physics; that he was an atomic physicist; that he was an anthropologist; that he was a civil engineer; that he attended postgraduate studies at Princeton University.

Q All right. What about his activities? What is your claim on that?

A The claim that he had done the first complete mineralogical survey of Puerto Rico: that he had supplied hydrographic information to the Hydrographic Office from his Caribbean cruise; that he had rewritten the Alaskan Pilot; that he had been the initiator of LORAN; that he had supplied underwater pictures to the university of Michigan; that he had studied several savage cultures.

Those are what I recall right now.

Q All right. And is there anything else on his activities?

A I’m sure there are more.

I believe the list is very extensive. That is what comes to mind at this moment.

Q And then I understand that you claim that there were misrepresentations, scientific misrepresentations, representations that were claimed to be scientific; is that part of what you are contending?

A I assume you mean the scientific claims regarding the workability or the guarantees offered by Dianetics and Scientology?

Q I don’t know, I’m trying to find out what you mean. I don’t mean anything except to ask you the question to find out what you mean.

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A Okay. In my mind there are those misrepresentations regarding the subject.

Q regarding the claims that Scientology can accomplish?

A That it can raise I.Q, a point per hour; that it can cut reaction time by 30 percent.

Q Are those the only two? Are there other things that you claim are misrepresentations?

A I think there are a great number; that it can produce a state of Clear; that it can produce a state of OT where a person is knowingly a cause over matter, energy, space, and time. Those are scientific claims.

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Q Any others or are those the key ones?

A There are many others; that it can cure a common cold; that a Clear cannot get a cold; that it can cure arthritis.

Q Okay, and it is your contention that these documents show these claims to be false; is that right?

A The documents show Mr. Hubbard making the claims. I am the proof that they are false.

Q You are the proof that they are false because those things –

A I had a thousand hours of auditing, and I am not a thousand intelligent quotient points smarter.

Q Okay. All right, so, you are the proof and I take it other former Scientologists are the proof that these claims about Scientology are not correct; is that right?

A I think that I am and they are certainly a part of it.

Q But let me see if I understand this correctly.

Is it also your claim that the documents show that these things are not true?

THE COURT: When you say "things," he’s talked about a lot of things, Counsel.

Q BY MR. LITT: I mean the complete set of these claims about what Scientology can accomplish.

A I believe that they will show that they are part of that proof.

Q Is there anything else that you claim has

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been represented scientifically that you claim is a misrepresentation?

MR. FLYNN: For the record, Your Honor, I don’t believe any of this was gone into on direct, but I have no objection to it.

MR. LITT: Well, he talked at length about science and I am just trying to understand what we have here, what the claims of misrepresentation are that he took the documents in order to defend himself about it.

THE COURT: Well, it becomes rather convoluted the way it is being phrased.

I trust that this is not simply discovery for the upcoming fraud lawsuit.

MR. LITT: No, it is not. The problem is, Your Honor, that there are hundreds of documents. We are trying to understand what it is that is supposed to be in issue.

THE COURT: Well, he didn’t even talk about, as I gather — he refrained from discussing the truth or falsity of doctrines of Scientology. That would not be something that is triable under the First Amendment, and they have refrained from getting involved in that, but I guess if you want to keep asking about it, he will probably tell you his opinion about it.

MR. LITT: No. The problem is, Your Honor, he’s said in his direct examination that Scientology has held itself out to be a science and that is false. I can find the court four or five different places, so we are left with this general statement that Scientology is claimed

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to be a science.

THE COURT: I can remember him reading Mr. Hubbard’s statement that it is a science and not something else, and then saying that it is something else and not a science. I gather if that is what you want to know, yon can ask that.

MR. LITT: I am just asking for what his contentions are. we don’t intend to go into all of this, but we just want to understand what are the purported misrepresentations.

MR. FLYNN: They are set forth very explicitly in exhibit double V, so Mr. Litt need only go through the four pages of exhibit double V line by line.

THE COURT: I agree with Mr. Litt. He’s got a right to cross-examine.

I agree with Mr. Flynn that we may be wasting a lot of time. If you want to refer to that list and ask him whether those are the ones, go down one by one, it would be one way of doing it.

MR. LITT: It would be longer than what I am trying to do is to get some categories which I am almost done with.

Q The next area I gather is moneys from the church supplied to Mr. Hubbard. You claim there have been misrepresentations about that?

A Yes.

Q And about the control of the church by Mr. Hubbard?

A Yes.

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Q And on the question of moneys, what do you claim are the misstatements?

A That Mr. Hubbard was not receiving any money from the organization; that he was getting paid less than a staff member. That is principally it.

Q All right, and then I understand that this question of "Dive Bomber" which I won’t go back into, but you claim that is a misrepresentation.

Now, have I covered in the list we have just gone through, have I covered the main areas or have you covered the main areas that you claim constitute misrepresentations concerning Mr. Hubbard?

A Those are what come to mind right now. I think that ultimately another area will develop, and that is Mr. Hubbard’s intention and what exactly he set up the Sea Organization and Scientology for.

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A I believe that those things are being misrepresented. They were misrepresented to me and misrepresented to the public.

Q Referring to the fact that it was set up for Scientology and you claim it was set up for him personally, is that the idea?

A More that it is an intelligence mechanism by which he can obtain control over people.

Q Okay. All right. Mr. Armstrong, now, let’s go to the time when you first came into contact with Scientology; you were in Vancouver at that time; is that right?

A Chilovac, British Columbia.

Q And do you recall when you first and in whatever form were introduced to Scientology? Do you recall as specifically as possible when that was?

A The first time was a magazine article. I believe it was in the Star Weekly Newspaper, in the magazine section on the weekend. And would have been — I don’t know the year, maybe ‘67, maybe earlier than that, maybe ‘65, ‘66.

Q That it had been written?

A That it was published.

Q But you first read it in ‘69?

A No. I first read it — that was the first time I had ever seen the word Scientology.

Q And at that time nothing came of it; is that correct?

A That is correct.

Q All right. Now, at some point — and my question

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now is just at what point — in 1969 you came in contact with something having to do with Scientology which ultimately ended up with your becoming involved in Scientology; right?

A Yes.

Q When was that?

A That would have been in the late spring, early summer of 1969.

Q And at that time what were you doing?

A I was at that time logging for a living in British Columbia.

Q And you had been a student prior to that and had dropped out of school; is that right?

A That is correct.

Q And were you in Vancouver where you were doing the logging, or were you in a more rural area?

A Well –

Q Or do I just not understand the geography of Canada?

A I was logging — I was living in a logging camp at that time out in the bush, out in the woods.

Q And was it at the logging camp that you had some further contact with Scientology, or were you in the city, or what?

A No. I came home for a weekend. Home was Chilivac at that point.

Q Okay. And what form did the contact that you had at that point with Scientology take? Were you given a publication again, or what?

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A No, I was told about it by two friends of mine. And they told me about another person who we knew who had just come back from Toronto after being involved with Scientology for some time in Vancouver and Toronto.

Q So these two friends had a discussion with you and then did you decide to seek out Scientology in some form to find out more about it?

A Then I spoke to the person who was himself — who had been involved in Scientology for a number of years.

Q And this was a social conversation; did you know the person?

A Yes.

Q And where did this conversation occur? Do you remember?

A I believe the first time I met the person was at a lake near Chilovac.

Q And do you remember his name? Was it a he?

A Yes. His name was Roger Benett.

Q And the two people that had told you about what he had been doing, do you remember their names?

A One was Doug Brown and one was Gordon Harris.

Q So you met with Roger Benett and he told you about Scientology?

A Yes.

Q What did he tell you about Scientology?

A He told me that — we spoke for some days on the subject at that time.

He told me about Clear.

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He told me about auditing.

He told me about L. Ron Hubbard.

He told me about Sea Org.

He told me about OT.

He told me about his own auditing.

He told me about how the mind worked according to Mr. Hubbard.

He told see about how auditing worked relative to the mind.

He told me about the exactness of it.

He told me about the power of it, about the powers of operating thetan or OT. That was mainly it.

Q Now, you said that you had conversations over several days; were these — did the two of you just get together and discuss this subject for several days, or what?

A Through the next month or so, I saw him several times often for many hours at a time. He gave me the books out of his library at that time.

Q Which books were those?

A Brahms works; 8-80; 8-8008; New Slant on Life; Dianetics and Modern Science of Mental Health.

There was another several books. He had a complete library of books that were published to that date.

Q These are the books that you recall him giving to you?

A Yes.

Q And in the course of that month period while you were having discussions with him, did you read these books?

A I read a lot of them, yes.

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Q All right. Now, so, you met him someplace and started this discussion which turned out, as I understand it, to be 1ike a month-long discussion about whether — about Scientology which I gather you found interesting and wanted to pursue at the time; is that correct?

A The conversation was not a month long, but we met several days ever the course of a month, at the end of which I went to the Scientology franchise in Vancouver, but –

Q I understand. I don’t mean that you had a literal 30 days in a row conversation, but in the course of a month you had several, several hour conversations; correct?

A Yes.

Q All right. Now, you listed a whole range of things that he told you about. Let’s take a few of them.

You say that he told you about the state of Clear; what did he tell you about that?

A That a person who was Clear had no reactive mind. Could not be stimulated by external stimuli. He was in total control of his mind. Could not get sick.

Q And I take it he told you what the reactive mind was in Scientology?

A Yes.

Q And what did he tell you about that?

A That the reactive mind was the accumulation of incidents of pain and unconsciousness and the incidents

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connected to that. He explained to me ingrams, secondaries and locks.

Q And he told you about auditing, the relationship of auditing to these concepts that you have just been describing?

A Yes.

Q What did he tell you about that?

A About the process of auditing, repetitive processes, of earlier similar processes, of erasure and of obtaining the — something called basic basic, and in that way the eradication of the reactive hind and the production of the state of Clear.

Q And you mentioned, I think, that he told you something about his own auditing; is that right?

A Yes.

Q And what did he you about that?

A He had been audited in Toronto and he had been audited on - what he told me about was the first couple of grades. I remember him telling me about grade zero.

I believe it was grade zero communications release and the fact that he had become a communications release in a matter of three seconds.

Q And did he — you say that he talked about the operating thetan; is that right?

A Yes.

Q Did he talk about what the thetan was?

A Yes.

Q What did he tell you about that?

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A That the thetan was the entity that controlled the mind, used the mind for the control of the body and was the entity that viewed the pictures in the mind, and that this entity could be knowingly exterior from the body and that that was the state producable in Scientology, and that an OT could operate the body knowingly from outside the body and could leave the body at will.

Q Did he tell you that thetan was a notion of the spirit being independent of the body or soul or whatever phrase you want to use, something like that?

A Well, no. He spoke in very scientific terms and he quoted from the factors and from the axioms of Scientology and his description was more along the lines of the axioms, not located in space and time kind of description, able to postulate and perceive. Not so much that it was a spirit in the religious sense, but that it was a scientific, definable term and he spoke in those kinds of terms.

Q And then he described to you the powers of an operating thetan. What more did he describe to you than you have already told us about that?

A He went into the control over matter, energy, space and time, the fact that these OT’s could be where they wanted and do what they wanted.

Q And did he tell you anymore about how the mind worked than what you have already described as you recall?

A Yes. We spent a great deal of time going over the consecutive record of mental image pictures, the

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time track, how it vas created, how it is alleviated, the process of auditing.

THE COURT: Well, we are going to take a 15-minute recess.

(Recess.)

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THE COURT: Let the record show that counsel are present; the witness has retaken the stand.

State your name again for the record, sir. You are still under oath.

THE WITNESS: Gerald Armstrong.

THE COURT: Mr. Flynn.

MR. FLYNN: If Your Honor please, I have borrowed this book from someone that is dedicated to Alexis Valerie Hubbard.

And I would like to give it back to her and enter Xeroxed copies of the dedication page of three separate printings of the book from ‘51 up to 1956, if I could.

THE COURT: Mark these Xeroxed copies as next in order,CCC.

Counsel, do you have any objection to that procedure?

MR. LITT: No, Your Honor.

THE COURT: All right. For the record, what is the name of the book?

MR. FLYNN: Science of Survival by L. Ron Hubbard; first edition of which is copyright 1951 by L. Ron Hubbard.

THE COURT: Very well.

You may continue, Mr. Litt.

MR. LITT: Thank you, Your Honor.

Q Mr. Armstrong, when we were talking about this series of conversations that you had with Mr. Benett, do you recall anything else that he told you concerning the general philosophy or belief, the system of Scientology in this series of discussions that you haven’t described already?

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A The only other thing that I recall, he talked about something called "Spinning the paradox of life and death." And what that was, I never did find out from him or I could never quite phathom it until possibly many years later. But he went on at some length about it. That is the only other thing that sort of sticks in my mind from that period.

Q And you said that he told you something about Mr. Hubbard; do you recall anything be told you about Mr. Hubbard?

A That he was on board the ship, the Apollo; that he was in the Mediterranean at that time; that he was the sole developer of this whole thing; that he was OT; that he was — Roger, used the name synthesized, synthesized the Eastern philosophy with the Western scientific approach, something like that.

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That was mainly it at that time.

Q Now I gather that after this series of discussions, that you were interested in pursuing Scientology more; is that correct?

A Well, I was interested in finding out about it. At this point I went and talked to a Scientologist in Vancouver.

Q All right, and who was that; do you recall?

A My first contact was with someone and I seem to recall his name was Hanson. I don’t recall his first name and I only saw him this one time down in Vancouver.

He was an OT-6 and that had particular significance at that time because that was the highest level of OT which had been released by Mr. Hubbard that I knew up to that time, so it was significant that I met this gentleman in Vancouver.

I spoke with him just a very few minutes, and that was the last time I ever saw him. I had long conversations and attended lectures shortly thereafter.

Q And these were in Vancouver at the Little Mountain Mission or franchise or whatever?

A Yes.

Q And in attending the lectures, you were still working at the logging camp and coming down the weekends; is that it or evenings?

A Well around that time I had moved from a different logging camp. I was logging up in a different part of British Columbia, and I had a different home in

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Chilovac, so it was just the first few times I went down to Vancouver on weekends.

Approximately the beginning of September 1969 I moved to Vancouver and got a completely different job and started attending lectures, and shortly thereafter got involved with Scientology on a continual basis from then on.

Q The lectures that you attended, do you recall who gave those?

A The person who lectured at that time was someone by the name of Graham Leese, and he was the owner and executive director of the franchise.

Q And he was the man one who gave the lectures?

A Later there were other people, another person by the name of Kingsley Wimbush lectured, and there were a few people throughout that period who gave lectures.

Q And the lectures, the general topic of the lectures, what was the general topic of the lectures?

A It was mainly selling courses, the next course to be taken.

Q I am not sure I understand. You said you attended a series of lectures. The series of lectures wasn’t about Scientology. It was about some other course that people should take?

A No, it was about Scientology, but the aspect of Scientology that it was about was the next course.
In Scientology there is a series of courses which one takes, series of steps, a gradient into and out of Scientology,

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and I was being lectured to about the next course that I should take; initially the first course and then a second course.

Q In the course of the lectures, was there discussion about the various tenets or beliefs in a general way of Scientology on certain topics, similar to what you have talked about with Roger Bennett?

A I think similar to that, yes.

Q And then did you after hearing those introductory lectures, did you take a course?

A Yes.

Q And what was the name of that course?

A It was called the Communications Course.

Q And then you completed that course, and then did you take another course?

A Yes.

Q Now what course was that?

A It was called the HQS or Hubbard Qualified Scientologist Course.

Q And those courses were also on the subject of Scientology and Scientology belief system on various topics?

A The initial courses were a series of drills which were done. Information was provided prior to doing the drills and then drills were done.

Q Okay, and after you took these two courses, you decided to join the staff of the Little Mountain Organization?

A Some time after that I actually came on and

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got paid as a staff member and that was after I began the, I guess, the third course which was the — called the Hubbard Standard Dianetics Course.

Q All right, and when was it that you made the decision to go on the staff of the Little Mountain Organization?

A Some time in 1972 — I am sorry, 1970. It would have been fairly early in the year, maybe April.

Q Now at that time had you concluded that Scientology offered something that at that point made sense
to you?

A Yes.

Q And that it offered something like it would help you and help others?

A Yes.

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Q And were there things in your own life that you were trying — problems in your own life that you were trying to solve at that time that you felt that Scientology would or had been helping you solve?

A That it would help me, yes.

Q How about had your experience for this, I guess, six-month period indicated that it was something new in the contacts that you had had with it to date as you viewed it then?

A Yes.

Q And had you had any auditing at that point, the point in April, 1970 when you went on staff; had you participated in auditing?

A Around that time, either just prior to during that period — no. Actually, before I went on staff I began auditing, I received what is called the Scientology grades.

Q Okay. And how many hours of auditing had you participated in at the time that you went on staff if you recall?

A My recollection is 40 hours.

Q And had you at that point found that auditing, along with Scientology in general, was something that seemed to you to be useful for yourself and others?

A I thought so at the time.

It was much more that it promised a usefullness. I had not solved what I felt was where I was at, the problem which was essential to me. I was told after doing the auditing steps, that that would only happen at Clear.

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So I felt like it was a gradient that I was going up and sooner or later what I sought would happen.

Q All right, Now, when you say it hadn’t yet solved the problem or problems, I don’t know for sure, that you were interested in, in a general way, what was it? What were the things that were of concern to you at the time that contributed to your joining Scientology?

A I perceived that I did not really experience things in the sense that things would logically be experienced; but that I experienced the experience. I was one step removed from experience. I lived in concepts, not in the reality of the world.

I knew that I was not courageous enough to step outside that, And I sought in Scientology the vehicle to get outside that and to be honest and to be courageous enough to live in the reality of the world.

I was promised that at Clear, that that stage was altered and that out of that would grow the courage to be able to live in the reality and not live out of experienced experience or concepts.

Q All right. And at the time you concluded that based on your experience with Scientology, up to that point, that Scientology would help you to accomplish this thing; is that correct?

A This was the state of Clear –

Q No, no. My question is did you conclude in April, 1970 that Scientology would help you to solve these problems that you were concerned with?

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A That Scientology would resolve those problems.

Q Would help you to deal with those problems.

A Yes.

Q Now, were there any other factors? For instance, did you feel that Scientology would help solve society’s problems?

A Yes.

Q And did you feel that Scientology would help to deal with problems of drugs?

A Yes.

Q Had you been told that Scientology was opposed to the use of drugs at that time?

A Yes.

Q And did Scientology in any way help you in a personal sense to deal with any problems of drugs that you may have had?

MR. FLYNN: Objection, Your Honor.

THE COURT: That is rather assuming some facts not in evidence. I’ll sustain the objection.

Q BY MR. LITT: In terms of the question of drugs, was there any change for you after coming into Scientology with respect to your — prior to Scientology, and without asking you any details, had you used any drugs at all?

A Yes.

Q And Scientology helped you to stop using drugs?

A I had stopped using drugs prior to my getting into Scientology, I did not use drugs through the time that I was in Scientology.

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Whether or not a conclusion can be drawn from that, I don’t know.

MR. LITT: May I see exhibits N, R, S, and P?

THE COURT: Are you talking about exhibits that are under seal?

MR. LITT: No; N, R, S, and T are the regular markings. I don’t believe that any of these are under seal.

Q Now, Mr. Armstrong, showing you exhibit N which is a document entitled "PRO News" that you testified about in the course of your direct examination, that particular copy of that publication, is that your copy?

A No. This is Mr. Flynn’s copy.

Q So Mr. Flynn showed this copy to you at some point?

A Yes.

Q When was that?

A Maybe a month or so ago.

Q And how about exhibit R which is a magazine entitled "Successes of Scientology"; is that your magazine?

A No.

Q And when did you first see that?

A In Vancouver.

Q I mean this particular one.

A Oh, at the same time, from Mr. Flynn.

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Q And with respect to Advance 7 which is exhibit T, is it true that you first saw this particular copy from Mr. Flynn about a month ago?

A Yes.

Q And with respect to exhibit X which is entitled "Scientology, The Field Staff Member Magazine" you first saw this about a mouth ago?

MR. FLYNN: You mean as opposed to –

Q BY MR. LITT: This particular document.

A Yes.

Q At the same time did Mr. Flynn show you other documents or publications?

A Yes. We saw some others during that time, yes.

Q All right now as I understand your testimony, you have a specific recollection that you saw the "PRO News" dated April 1970 in Vancouver?

A It is either this one, one real similar, but in any case I have seen this very early on in Vancouver.

Q But do you remember when you saw it when you say early on?

A 1969, 1970.

Q You think you had seen the biography earlier?

A Right.

Q Do you know whether you had seen this PRO News itself or only the biography?

A It was either this or another one similar, very similar to that. I don’t recall all the notes on

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the front because I saw so many of these things, but I definitely saw with this story in Vancouver.

Q All right. Then, exhibit R, this booklet entitled "Successes of Scientology" you have a particular recollection of having seen that?

A Yes, in Vancouver.

Q A copy of that?

A Yes.

Q Do you remember when that was?

A No, it would have been around the same time.

I think both of these publications, this one and that one, were on sale or they were sold in the Scientology Mission. I believe they sold for either a dollar or 50 cants each at that tine, but I bought both of these.

Q Okay, and you read them?

A Yes.

Q So you read not only the biographical part, but the contents?

A Yes.

Q And exhibit R, the contents deal with, do they not, statements from a variety of people about their experience with Scientology and how it helped them?

A Yes.

Q Okay, and you found that of significance?

A Yes.

Q And exhibit S, I take it you also read the contents of that; is that correct?

A Yes. I don’t know if I read every word,

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but I would have gone through it, yes.

Q And the booklet itself is approximately 40 pages, 39 or 40 pages long if you include the back; is that correct?

A Yes.

Q And it discusses a variety of things about Scientology’s belief system; does it not?

A Yes.

Q Discusses, for instance, the eight dynamics?

A Yes.

Q And what are the eight dynamics; do you know?

A The –

Q You don’t have to describe every one.

A It divided up the human existence into eight parts, divided up the urge for survival into survival along eight separate dynamics or eight distinct parts or paths.

Those are the eight dynamics.

Q Okay, and they go through a range of things including one’s self, family, group, et cetera, is that right?

A Yes.

Q And you read in here the information about the tone scale; is that correct?

A Yes.

Q And an article called — there are articles called "States of Existence," "Road to Clear," "Scientology Training," "The Reactive Mind."

You read those things — "Dianetics"?

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A Yes.

Q And in this exhibit T which is approximately — it doesn’t have numbered pages, it looks like it is about 16 pages. Similarly it has a variety of articles on Scientology and different reports about Scientology and what it stands for or experiences within Scientology organizations or what Scientology organizations do?

A Yes.

Q And you read those as well?

A Yes.

Q And this "Advance 7? do you recall when you read that?

A I believe I saw that same "Advance" while in Vancouver.

Q Do you recall when?

A 1969 or 1970.

Q Now, Mr. Armstrong, you joined staff in April 1970 and what were your duties?

A I sold books. I gave lectures. I gave courses. I wrote letters. I mimeographed issues. Took care of files. I cleaned the building. I sold courses and took care of the banking.

Q And did you do more auditing during that period as well?

A I believe that the auditing which I was involved continued on past the point of my joining staff, yes.

Q And I believe you said that up until April 1970 you had about 40 hours of auditing. Taking the remainder

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of the year, about how many more hours of auditing did you have?

A I don’t know if I had any more during that year.

Q You can’t recall?

A To the best of my recollection I had 40 hours.

There may have been some hours of what is called review.

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A When the auditing doesn’t work a particular way, a review of that auditing is done. And there are various procedures that are gone through until the person gets the desired result.

So I complained at one point that I did not get the desired result and I had some of this review auditing. My recollection is that I used up the 40 hours which were allocated for the — for this auditing. I only paid for 40 hours. And I would have had to pay for more hours to get more auditing. I think it ended at 40.

Q Okay. Let’s take the courses that you say you lectured; you gave lectures; is that right?

A Yes.

Q And did these lectures have a title?

A I don’t believe so.

Q Well, these lectures were for new people who were coming in and being introduced to Scientology?

A That’s correct.

Q And you gave lectures similar to the lectures you had heard some months before?

A Yes.

Q And in these lectures what would you tell people in general?

A Information from the communications course that I was selling what auditing was; what the promises of auditing were. That was mainly it.

Q And did you give them a general description of how auditing worked and the concepts of the mind that we have

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already talked about as it pertains in Scientology?

A Yes.

Q Basically, you gave them the kind of review that you have described that Roger Benett gave to you, perhaps not as such depth, but some of the various elements of Scientology belief; correct?

A Yes. My lectures were mainly about what the courses that a person would take would be about.

Q Okay, And then this course, the communications course, it also had another name; didn’t it?

A Not at that time.

Q Subsequently it had another name; didn’t it ever have the name "The Hubbard Apprentice Scientologist, A Scientology Course"?

A Yes.

Q But that was afterwards?

A I did not hear that name until I had left the Vancouver area.

Q And you taught this communications course; is that correct?

A That is correct.

Q And the communications course, among other things, was designed to introduce people to certain fundamental concepts within Scientology; is that correct?

A Yes.

MR. FLYNN: Your Honor, I object at this point. We spent several days — I don’t know whether this is a First Amendment area or not.

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But Mr. Litt argued pretty vehemently against going into anything having to do with the philosophy or religion of Scientology itself. Whether it is or not, it is hard for me to tell the way the questions are framed. I don’t believe this has been the subject of direct, number one.

If Mr. Litt is waiving his claimed First Amendment Rights on this issue, I think the record should show that. I don’t see any relevancy to this whole line of questioning on philosophy.

MR. LITT: It has been claimed here that Mr. Armstrong entered and participated in Scientology based upon what he had been told about Mr. Hubbard’s background. We are establishing — and I think have largely established already — that he joined Scientology because what he had learned about Scientology made sense to him at the time.

We are not going into whether any of these things are correct or not or true or false, but simply what his state of mind was about what he told people about, what he did, what he learned, what his motivation was for joining. I think in light of this claim that has been made throughout this testimony, that –

THE COURT: I’ll overrule the objection.

This is only your first day, I don’t expect to spend the rest of my life on this case. Let’s try to move it along.

MR. LITT: I agree, Your Honor. We’ll move through this period. But we want to show what his general experience

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and attitude was in Scientology. I think there has been testimony about characterizing it a certain way.

THE COURT: All right.

Q BY MR. LITT: And in the courses that you taught, among the concepts that you taught were concepts about Scientology’s view of the mind; is that correct?

A Yes.

Q And Scientology’s view of the thetan?

A Yes.

Q And the notion that the thetan is the individual himself and not the body or the mind?

A Yes.

Q And what, that Scientology is — well, the relationship between Scientology and Dianetics?

You can answer yes or no. We don’t need –

A It may have been mentioned. That varied according to time. And I really can’t say what the relationship was at that time or even if we covered it in lectures.

Q Okay. What did you tell people about what Scientology itself was? If people asked you for a one-line definition of Scientology, what would you tell them?

A The science of knowing how to know.

Q And you also explained the concept of auditing to people and how auditing worked?

A Yes.

Q And you then spent time discussing with people about how to improve communications; is that right, between people?

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A Yes.

Q And how people could learn to communicate with others better using Scientology?

A Something to that effect, yes.

Q All right.

Now, you said that at a certain point you had somebody come and talk about the Sea organization; correct?

A Yes. There were two lectures that I recall concerning the Sea organization to some degree at least.
One of them was a specific Sea Organization Mission. And one of the purposes of which was recruitment.

The other one was another Sea Organization Mission, but it was for some other purpose; although recruitment was, again, a part of it. And I don’t recall what the — it was an event of some sort and there was — I don’t recall what else was being promoted at that time, but there was something else.

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Q Okay, and in general, you were told that the Sea Organization was a group of highly dedicated Scientologists who had committed their life to Scientology; is that right?

A There was such a concept. The way it was promoted was usually the people who are working directly with Ron, getting in ethics on the planet.

Q And getting in ethics was a reference to Scientology concept? In other words, people were saying that people in the Sea Org were working directly with Mr. Hubbard and using Scientology to help the world, something like that? That is what you believed: wasn’t it?

A Well it was more along the lines of the world is an unethical place. There are enemies of mankind who are destroying the planet and the resolution of that is to get in ethics, to make it an ethical environment in which honest actions can have rights.

Q So it was your understanding that the Sea Org was made up of a group of dedicated people who worked with Mr. Hubbard who were trying to deal with the situation on the plant that you have described?

A That is correct.

Q And to change it for the better as you understood it then and as it was presented to you?

A Yes.

Q All right, and after hearing this, do you recall who were the people who did this — gave you these talks?

A The first one that I attended, I can’t tell

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you which came first, but any recollection is that the first one was Heber and Yvonne Jench. They may not have been married at that point, so it may have been Heber Jench and Yvonne Gillam, but they mere definitely the main people involved in the main event, and the other one was Laurel Watson. She gave a talk, a lecture.

Q And I wasn’t sure whether you said one of these were sort of mainly focused on the Sea Org itself; is that right?

A That is the talk given by Laurel.

A Okay, and as a result of hearing these and your experience in Scientology, you decided to make this commitment and join the Sea Org; is that right?

A Yes, some time around that.

Q And I take it that at the time you were enthusiastic about doing this?

A Well, I don’t know if enthusiasm is the correct emotion there. I think maybe I was so frightened that I did it.

Q You made the decision before you were in the Sea Organization to join it because you were frightened about what would happen to the world if the Sea Org didn’t accomplish its mission; is that what you are referring to?

A Yes. If every Scientologist didn’t do everything he could to help Ron clear the planet.

Q And at the time you agreed that that goal of clearing the planet was a positive goal?

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A Yes.

Q But nonetheless you made this decision to commit your whole life to this and you weren’t enthusiastic, simply afraid; is that your testimony?

A I think that is a great deal of a motivation, a great deal of a motivation which kept me in for so many years. I think I possibly –

Q Right now we are talking about your joining the Sea Organization.

A I am explaining that.

Q Okay. So your testimony is that you joined the Sea Organization because you were afraid?

A I wanted to do whatever I could. I had to overcome a great deal of fear to do that, but I wanted to do whatever I could to help this man clear the planet, to make it an ethical environment, to bring honesty and integrity to planet Earth.

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Q Right. But your characterization of that is that you did all of this and made your commitment because of fear; is that right?

A I am saying that fear was a part of it.

I was being told that we had better get ready because death’s dark curtain is about to descend on this planet. And there is a great deal of fear wrapped up with being in Scientology.

I had — the future of the earth depended on what I did right there and now in Scientology, quote Mr. Hubbard.

Q What you and others did?

A Well, what I as an individual did.

Q Okay. So you were afraid; you made this life long commitment and you left Vancouver then and flew to Los Angeles; is that right?

A Yes.

Q And you did all of this very rapidly; is that right?

A The leaving Vancouver, the flying?

Q Well, from the time that these recruitment speeches that you heard, speeches for people to come into the Sea organization until the time that you went to Los Angeles, how long a period was that?

A I went back logging for a period of that time to make some money. And I sold everything that I had and bought what was necessary for joining the Sea organization and went off and joined.

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It probably took — it was over several months.

Q Okay. So when did these talks from Laurel Watson and Heber and Yvonne Jench occur?

A During two points in 1970. I don’t recall the exact date, but they predated my leaving.

Q All right. Now, you went to Los Angeles and then shortly thereafter you, along with several other people, were sent to the Mediterranean; is that right?

A We were flown to Madrid, Madrid, Spain, and down to Algeciras which, I believe, is on the Atlantic side of the Mediterranean.

Q Did you make that trip from Los Angeles to Madrid with other people?

A Yes.

Q Who were those people?

A One of them was named Amanda Struan; one was named John Murphy; one of them was named Jim Hausen and there was another one. I think his last name was Rivera. But I don’t recall his first name. It is a Latin name.

Q Okay. And did all of those people then travel to the ship with you?

A Yes.

Q And was the ship in Madrid at the time, or did you have to travel some place else to get to the ship?

A No. The ship was in Tangiers, Morocco.

Q You traveled there by water?

A We flew to Madrid, took the train from Madrid to Algeciras and from Algeciras across by ferry to Tangiers;

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across the Straits of Gibraltar.

Q This was 1971; what month?

A Early February, 1971.

Q Okay. Now, I am not going to spend much time on the ship, but I have a couple of questions on that period.

You described some duties you had where you were in charge of greeting the people who you would meet at various portal was that the port captain? Was that –

A I did that regularly from about 1972 through 1975. But it depended on which position I was holding at the time as to who I would meet when I was the ship’s rep.

I generally met — when we arrived into port, I would meet the pilot; then the port guard and customs agent and the port authority for clearing the ship into port, submitting all the documentation necessary for the clearance of the vessel into the country.

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Q Now, were part of your duties at certain points to transport people when the ship was docked, to drive people to various places? There were vehicles on board the ship; right?

A I would have been doing the transport of people during an early period of time when I was — first of all when I was called the ship boats and transport in charge which would have been approximately February or March.

Q Let me interrupt you because we can short circuit some of this. I really am looking for brief answers. Were some of your duties that you would drive people around at various times? That is all.

A Not when I was greeting these port officials — yes.

Q Now your testimony on direct was that throughout the period of time that you were on board the ship you were in fear; is that right? I seem to recall some such testimony.

A Yes.

Q Was this the same kind of fear that you have described before that you just described earlier that you were afraid for humanity or what would happen to the planet?

A There was a lot of, I think, a lot of factors, a lot of fears of different things.

I was afraid of not making it.

Q "Not making it" in Scientology, you mean?

A Yes; not being a good Sea Org member, a fear

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of being RPF’d, fear of being SP, fear of falling out of favor with L. Ron Hubbard.

There was a number of factors like that which did not create a state of peace of mind.

Q Now at some point did you leave the ship before the ships themselves stopped sailing?

A I am not quite sure –

Q Didn’t you and your then wife, Terry Gamboa, at some point take a trip off the ship for some period of time?

A Yes.

Q When was that?

A In, I believe, September of 1975.

Q Okay, and you went to see your parents; is that right?

A Yes.

Q And it had been reported to your parents, had it not, that something had happened to you, either that you had been killed or you had been shanghaied; is that right?

A Yes.

Q You and Terry went to see your parents to reassure them that you were all right; is that right?

A Yes.

Q And how long were you on this trip?

A The segment to Canada?

Q Well, were there other parts to the trip as well as the trip to Canada?

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A Yes. We also visited Terry’s parents. Her mother was living in Los Angeles. Her father was living in Phoenix.

Q In total the trip that you took?

A About a month.

Q So you and Terry were gone for about a month; correct?

A Yes.

Q And you visited both your parents and Terry’s parents and reassured them, did you not, that you were fine?

A Yes.

Q And you talked to them about Scientology; correct?

A Yes.

Q Tried to make them feel comfortable with the fact that you were in Scientology?

A Yes.

Q And to assure them that you were happy in Scientology?

A Yes.

Q And that you liked what you were doing?

A Yes.

Q And that they shouldn’t be concerned about you?

A Yes.

Q And that you were doing what you thought was important to you?

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A Yes.

Q All right. Now you believed all those things when you told them that, didn’t you, or were you lying to your parents?

A I did lie to my parents regularly.

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Q I am asking you about this discussion; you believed those things, then, didn’t you, Mr. Armstrong, that you were telling me?

A I did — at a minimum. I believed that it was right for me to tell them that.

Q You are not answering my question.

A I know. It is a difficult question to answer.

Q You have got to try to answer it.

Didn’t you believe those things then?

A One of those things — yes; at least on some level I believed those things.

Q And you then voluntarily returned to the ship with your wife; isn’t that right?

A Yes.

Q Nobody made you return; you returned because you wanted to; is that right?

THE COURT: You have got a compound question there, counsel.

MR. LITT: I am sorry, Your Honor.

Q You returned because you wanted to; isn’t that correct?

A Yes.

Q Nobody forced you to return to the ship; isn’t that correct?

A That is true.

Q Now, Mr. Armstrong, you testified that you gave some books to your — I believe you said to your parents and also to someone else while you were on this trip that

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you have described; is that right?

A Yes.

Q And the name of this particular book that you gave is "Scientology a World Religion Emerges in the Space Age"; is that right?

A Yes.

MR. LITT: May we have this marked next in order, Your Honor?

THE COURT: Plaintiff’s 23.

MR. LITT: Your Honor, I am going to spend some time on this particular book. So if — it is up to the court; I can begin, but it is five minutes to 4:00. And so we can –

THE COURT: We might as well use the five minutes.

MR. FLYNN: Your Honor, may I register an objection to the use of any part of the book?

THE COURT: Well, I don’t know what the first question is. We’ll deal with the question when it is asked.

Q BY MR. LITT: Well, the first question is you gave people this particular book because you felt it would give them an introduction –

THE COURT: I don’t know that there is any evidence that he gave people –

MR. LITT: The people that I am referring to –

Q That is, your parents and somebody from Parliament or something like that?

A Yes. Actually, I took one to the member of Parliament, but he wasn’t there. So I ended up giving it

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to the chief of police of the town that I was from.

Q And you gave both of these people that book because you felt that it would give then a good general introduction to Scientology for someone who was not familiar with it and who hadn’t had any experience with it; is that correct?

A I think the prime motivatiou in giving them the book was because I was ordered to do so by the assistant controller for intelligence, Jimmy Mulligan. I was briefed by him before leaving the ship. And this was part of the DA materials which he provided to me and which I was to provide to the official who my mother had contacted in trying to find out where I was.

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Q But the reason for that was that this was a general introduction that would explain, it does explain basic concepts of Scientology that we have already talked about; right? Do you recall that?

MR. FLYNN: I am going to object. You mean the basic concepts as the witness now understands them?

MR. LITT: No, as he understood them –

MR. FLYNN: Or the basic concepts that he says are falsely represented?

MR. LITT: The basic concepts as he understood them at the time.

MR. FLYNN: Well it would call for speculation, too, Your Honor.

He said he did it on orders of a fellow named Mulligan, and Mr. Mulligan was attached to the intelligence unit, so he’d be speculating as what Mr. Mulligan’s intentions were.

THE COURT: Well t is ambiguous. It is not quite clear whose intentions we are talking about.

Q BY MR. LITT: You testified earlier, Mr. Armstrong, that you were generally familiar with this book; correct?

A Yes.

Q And you had at least read it in a — if not in detail, you had reviewed it, correct, before you gave it to your parents?

A Yes, not in detail but I had looked at it.

Q And you agreed at the time, didn’t you, that it presented a basic introduction for a non-Scientologist

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concerning several concepts of Scientology and information that would be helpful to understand Scientology?

A Well, that was a part of it. That wasn’t the way I was viewing –

Q My question –

MR. FLYNN: Your Honor, could the witness finish?

MR. LITT: The: answer is nonresponsive, Your Honor.

THE COURT: Well, then, let’s read the question back and listen to it carefully.

(Record read.)

THE COURT: Well it is a compound question and you asked if he agreed. You could ask him what his state of mind was. I don’t know, agreement involves two people usually.

Q BY MR. LITT: Your state of mind at that time, Mr. Armstrong, was it not that this book explained several basic ideas of Scientology?

A Okay.

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Q Right.

A At least to some degree, yes.

Q And it was presented in a way that you felt could be understood by someone who was not a Scientologist?

A Yes.

Q And so you then gave this book to your parents and to this chief of police, feeling that it would provide them such a basic introduction for a non-Scientologist; didn’t you?

*
On October 6, 1993, Armstrong 2 and 3 were consolidated. On September 12, 1994, Armstrong 2 and 3 were consolidated with Armstrong 4 under Marin SC No. 157680.
All are now called Armstrong 4.
On April 9, 2008, Armstrong 4 was consolidated with Armstrong 7.